Tremblay T.C.J.:

1 This appeal was heard at Québec City, Quebec, on January 15, 1997. The last written argument was filed on April 14, 1997.

Denault J.:

1 In June 1992, Groupe LMB Experts Conseils Inc. (Groupe LMB) owed Revenue Canada an amount of $394,527.90 that was still unpaid. On September 29, 1992, requirements to pay issued under subsection 224(1.2) of the Income Tax Act were sent to two of Groupe LMB's debtors: the Hôtel-Dieu de Roberval and the town of Mascouche. Shortly afterwards, these institutions paid the Receiver General of Canada the amounts they owed Groupe LMB: $44,009.98 and $50,503.03, respectively.