Although the Court agreed that a portion of the payment in question fell within the language of s. 212(1)(d)(i), the Minister had taken an all-or-nothing approach in his pleadings. Since the Minister had not succeeded in establishing the assumptions set out in his pleadings, his appeal failed, notwithstanding his partial success on the merits.
Topics and taglines
Topic
Tagline
failure of Minister to allocate
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
332860
Extra import data
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"field_legacy_header": "<strong><em>The Queen v. Farmparts Distributing Ltd.</em></strong>, 80 DTC 6157, [1980] CTC 205 (FCA)",
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