Kourtessis v. M.N.R., 93 DTC 5137, [1993] 2 SCR 53, [1993] 1 CTC 301 -- text

Gardiner v. Minister of National Revenue, 54 DTC 1015, [1954] CTC 24, [1964] S.C.R. 66 (SCC) -- text

KERWIN, J.:—This appeal raises only questions of fact, including, of course, the proper inferences to be drawn from established circumstances. For the reasons given by my brother Rand, I am of opinion that the trial judge came to the right conclusion, and

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