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The clear question which I am asked to decide is whether the defendant Bourassa has a good defence under Section 126(6) of the Income Tax Act by reason of the words therein, ‘‘... unless he is unable to do so.’’ ...

The stated case reads as follows: “ James Stewart Tyhurst was charged that he did, on the 14th, 15th, 16th, 17th, 18th and 19th days of November, A.D. 1960, unlawfully fail to file T1 1959 Income Tax Return, after demand under Section 44(2) of the Income Tax Act contrary to Section 131(1) of the ‘Income Tax Act. ... The extent of this meaning here is made more conclusive by the marginal note of the subsection, viz., ‘‘ Proof of Service by Mail’’. ...

Bissell has specified the following “ public interest" grounds (summarized): 1. Disclosure of this information would be injurious to the relationship between employees of Revenue Canada and legal counsel in the Department of Justice — resulting in reluctance to consult and discouraging full and frank discussion; 2. ... I have already suggested that cross-examination of Revenue Canada officials will determine the appropriateness of the action taken — a suggestion reflecting the receipt of advice in what counsel for the Crown calls “the most routine and ordinary context”. ...

(see James Richardson & Sons Ltd. v. Minister of National Revenue (1984), 9 D.L.R. (4th) 1 (S.C.C.) @ p. 9, per Madam Justice Wilson). ... Branch, [1995] 2 S.C.R. 3 (S.C.C.), at pp. 14-15: … the crucial question is whether the predominant purpose for seeking the evidence is to obtain incriminating evidence against the person compelled to testify or rather some legitimate public purpose... ... [signature] Deputy Commissioner Operations RCMP Date 92/01/14 “k” — The Protection of Information General 1. ...

Manning & Associates Inc. shall have the authority to compromise accounts receivable and debts in order to facilitate the collection of accounts receivable. ... The duty of the interim receiver is to preserve the debtor’s assets: Stuart & Sutterby, Re (1929) 11 C.B.R. 1 (Ont. ... Port O’Call Hotel Inc., supra, described the essence of the section as follows: “... s.224(1.2) provides a form of garnishment enabling the federal government to intercept monies owed to tax debtors.” ...

Pitfield made a further submission of a rather technical nature, but when one looks at the statute with a restrictive eye — and indeed, apart from the rule enunciated in Descoteaux, all taxing statutes are required to be interpreted strictly — it has merit. ...

:—This application requires resolution of an issue between Revenue Canada and the respondent, Parker Pacific Equipment Sales (” Parker Pacific"), each of whom assert a prior proprietary right to an amount of $9,776 paid by way of interpleader into court by the petitioners, Berg and Hazell. ... Nonetheless, notwithstanding the positivity with which Wright expresses himself, he does not deal with the findings in previous cases, in which a different result obtained that the legislation “ falls short of effecting a transfer of property in the funds or establishing priority of Revenue Canada's claim.” ...

I have, therefore, only had an opportunity of reading the short note in the above reporting service and, with respect, it seems to me that, even if a person were ‘‘otherwise legally entitled ’ to information which the Minister has obtained under the Act, that person is still faced with the statutory provision which gives the Minister a discretion as to whether he will communicate such information. The fourth subsection commences, ‘‘ An official or authorized person may... communicate, ete.’’ ... Lord Dunedin says, in. the case I have already cited, at page 423: “... ...

Edwards, an officer employed by the Department of National Revenue, served a letter addressed to: Heath Irving & Walton Attn: R.G. ... He pointed out the initial investigation section of the statute (then subsection 126(1)) referred to entry into any premises where ”... any books or records are, or should be kept pursuant to this Act... ... I note that the present version of subsection 126(1) (now subsection 231(1)) simply reads: where ”... any books or records are or should be kept... ...

In June of 1991, after receiving “ Requirements for Information” from Revenue Canada, the respondent retained the law firm Thorsteinssons in Vancouver to act for him in his dealings with Revenue Canada. 7. ...