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.
Lamarre T.C.J.:
1 These appeals, with respect to which the appellant elected the informal procedure, are against assessments of tax for the 1986, 1991, 1992 and 1993 taxation years made under the Income Tax Act (“Act”).
Décary J.A.:
1 These appeals raise the issue of the liability of W.R. McRae Limited (“the appellant”) to pay federal sales tax on goods sold to retail customers between July 1, 1990 and December 31, 1991. The goods were purchased by the appellant in one instance from an importer and in another, from a person other than the importer.
Rip T.C.J.:
Richard J.:
1 The Applicants commenced an application for judicial review pursuant to section 18.1 of the Federal Court Act by filing an originating notice of motion on November 22, 1996. They were represented by the same counsel.
2 The Applicants sought to set aside a demand for information under the Income Tax Act and the return of any documents concerning the Applicants obtained under paragraph 231.2(1) of the Income Tax Act.
Reed J.:
Brulé T.C.J.:
1 This is an appeal by Mr. Dubé concerning his 1986 and 1988 taxation years.
1) whether the Minister of National Revenue (the “Minister”) was barred from issuing the Notice of Reassessment dated May 29, 1992 in respect of the appellant's 1986 taxation year;
2) whether the Appellant received a bonus in the amount of $109,771 in the 1988 taxation year; and
Hamlyn T.C.C.:
1 These are appeals for the 1989, 1990, 1991, 1992, 1993 and 1994 taxation years. They were heard under the informal procedure.
Rip T.C.J.:
Margeson T.C.J.:
