Bowman T.C.J.:

Beaubier T.C.J.:

MacGuigan J.A. (Robertson, McDonald, JJ.A., concurring):

1 The applicant has not succeeded in persuading us that Hamlyn J.T.C.C. made any reviewable error of law. On a s. 28 application that is our only jurisdiction.

2 The application must therefore be dismissed.

Tremblay T.C.J.:

1 This appeal was heard at Montréal, Quebec under the informal procedure on June 25, 1996.

1. Point at issue

2 According to the Notice of Appeal and the Reply to the Notice of Appeal, the issue is whether in computing his income for 1994 the appellant was entitled to claim child care expenses amounting to $4,592.

Tradif D.J.T.C.:

Robertson J.A.:

Lutfy J.:

Bell T.C.J.:

1 All statutory references, unless otherwise specified, relate to the Income Tax Act (“Act”).

Issue:

2 The issue is whether, in the 1992 taxation year, payments made by the Appellant pursuant to an Order of the Court of Queen's Bench of Alberta are deductible pursuant to paragraph 60.1(1)(b) and/or paragraph 60(b) of the Act.

Denault J.:

1 The applicant, Les Produits de la Famille Anjou Inc. (“PFA”), is objecting to the seizure made by the Minister of National Revenue (“MNR”) on the property of Traitement d'eau Anjou Notre-Dame Inc. (“TAND”), owing the sum of $10,753.51 pursuant to a certificate of September 6, 1994. This debt resulted from source deductions not submitted by the debtor for the period from October to December 1992 and January to November 1993.

Gibson J.:

1 On the 14th of November, 1996, Mr. Justice Rouleau granted a “jeopardy order” in this matter in the following terms:

1. IT IS ORDERED THAT the Minister of National Revenue be and he is hereby authorized to take forthwith any of the actions described in paragraphs 225.1(1)(a) to (g) of the Income Tax Act in respect to the respondent.