T. Eaton Co. v. Minister of Revenue, [1989] 1 CTC 269 (Ont CA) -- summary under Agency

"I find it extraordinary that the respondent Minister would contend, through counsel, that Eaton's, as a statutory agent, would have a higher obligation to its principal than as an agent under the usual principal and agent agreement. Eaton's, as a vendor, is obligated by statute to collect and remit the sales tax but, after exhausting all reasonable means to recompense itself, I can see no reason why it, as the agent, should bear the loss rather than its principal, the respondent Minister."