| September 20, 1989 | |
| LEGAL SERVICES - TAXATION | RULINGS DIRECTORATE |
| Resource Industries | |
| Attn: C.T.A. MacNab | Section |
| General Counsel | John Shaw |
| 957-8968 | |
| File No. 3-2244 |
Subject: 24(1)
We enclose a copy an adverse decision - D & B Oilfield Contracting Ltd. v. M.N.R. - and the report thereon by counsel in Justice's Edmonton Office. While Judge Proulx did not find it necessary to establish whether a joint venture or partnership existed, the cases which she notes at page 8 of her decision may be of some interest to you.
Director General Rulings DirectorateLegislative and IntergovernmentalAffairs Branch
Enclosures