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Docket: 2001-1769(IT)G |
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BETWEEN: |
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ANATOLY EPEL, |
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Appellant, |
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and |
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HER MAJESTY THE QUEEN, |
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Respondent. |
_______________________________________________________________
Appeals heard on common evidence with the appeal of Anatoly Epel (2001-1771(GST)I) on November 28 and 29, 2002 and June 19 and 20, 2003
at Ottawa, Ontario
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Before: The Honourable Justice Diane Campbell |
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Appearances: |
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Counsel for the Appellant: |
Gregory Sanders and Julie Abraham |
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Counsel for the Respondent: |
Charles M. Camirand |
_______________________________________________________________
JUDGMENT
The appeals from the assessments made under the Income Tax Act for the 1992, 1993, 1994, 1995, 1996, 1997 and 1998 taxation years are allowed and the assessments are referred back to the Minister of National Revenue for reconsideration and reassessment in accordance with the attached Reasons for Judgment.
This case having been heard together with the case of Anatoly Epel (2001-1771(GST)I), only one set of costs is allowed.
Signed at Ottawa, Canada, this 20th day of October 2003.
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"Diane Campbell" |
Campbell, J.
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Docket: 2001-1771(GST)I |
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BETWEEN: |
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ANATOLY EPEL, |
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Appellant, |
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and |
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HER MAJESTY THE QUEEN, |
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Respondent. |
_______________________________________________________________
Appeal heard on common evidence with the appeal of Anatoly Epel (2001-1769(IT)G) on November 28 and 29, 2002 and June 19 and 20, 2003
at Ottawa, Ontario
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Before: The Honourable Justice Diane Campbell |
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Appearances: |
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Counsel for the Appellant: |
Gregory Sanders and Julie Abraham |
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Counsel for the Respondent: |
Charles M. Camirand |
_______________________________________________________________
JUDGMENT
The appeal from the assessment made under the Excise Tax Act, notice of which is dated November 30, 1999, and bears number 00000002220, for the period from September 1, 1991 to August 31, 1995 is allowed and the assessment is referred back to the Minister of National Revenue for reconsideration and reassessment in accordance with the attached Reasons for Judgment.
This case having been heard together with the case of Anatoly Epel (2001-1769(IT)G), only one set of costs is allowed.
Signed at Ottawa, Canada, this 20th day of October 2003.
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"Diane Campbell" |
Campbell, J.
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Citation: 2003TCC707 |
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Date: 20031020 |
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Dockets: 2001-1769(IT)G 2001-1771(GST)I |
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BETWEEN: |
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ANATOLY EPEL, |
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Appellant, |
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and |
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HER MAJESTY THE QUEEN, |
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Respondent. |
REASONS FOR JUDGMENT
Campbell, J.
[1] These appeals were heard together on common evidence. They are in respect to the taxation years 1992 to 1998 inclusive and involve both the Excise Tax Act and the Income Tax Act.
[2] In 1998 the Appellant was audited in respect to his 1992 to 1995 filed tax returns, on the basis of a net worth assessment. The Minister added the additional amounts of $71,351.00 for 1992, $70,817.00 for 1993, $56,713.00 for 1994, and $58,481.00 for 1995 to the Appellant's income in each of these years using the net worth method. The Appellant did not file returns for the 1996, 1997 and 1998 taxation years. For these years, the Minister prepared an arbitrary assessment, instead of a net worth assessment, and added $50,000.00 as income in each of these three taxation years. Penalties were imposed for the taxation years 1992, 1993, 1994 and 1995 in respect to the Appellant's understatement of his income in those years.
[3] The Appellant was also reassessed for GST for the reporting periods from September 1, 1991 through to August 31, 1995 in connection with the unreported business income arising out of the Minister's net worth assessment for this period. Penalties and interest were also imposed. The decision in the net worth assessment made under the Income Tax Act will of course determine this GST issue. It was also agreed between counsel in their opening remarks that my treatment of the taxation years 1996 to 1998 would follow my conclusions in the net worth assessment for the taxation years 1992 to 1995.
Facts and Evidence:
[4] The Appellant came to Canada with his wife and son from Russia in 1979. He was a shoemaker in his native country and in 1983 opened a shoe repair business in Canada. During the periods at issue in these appeals, he was the sole proprietor of this business, which was known as "Bells Corner Shoe Repair".
[5] The Appellant has little formal education and cannot read or write. He has a very basic working knowledge of the English language, which he acquired after his arrival in this country. However he is not proficient in the language and speaks with a heavy Russian accent. In fact he referred to his own mastery of English as follows: "... I can talk English a bit, as best what I can".
[6] The Appellant filed personal tax returns in 1992, 1993, 1994 and 1995 reporting income from his sole proprietorship. Because Mr. Epel could not read or write he stated that he kept "... each paper, each ticket and everything" and gave all these business items on a monthly basis to his bookkeeper to complete his records. He testified that he would not know if the record keeping was correct or not. He did not file returns in 1996, 1997 and 1998, although those returns have now been prepared by Mr. Epel's accountant and filed as representing his income from his shoe repair business for those years.
[7] According to the Appellant's evidence he started gambling in 1987 when he accompanied friends to a private casino in Hull, which was owned by John Turmel. Throughout the years in question he was gambling at various private establishments owned by Turmel in the Hull and Ottawa areas. John Turmel introduced Mr. Epel to the game of Texas Holding poker and taught him how to play. He played four to five times per week, Monday through Friday after 6:00 p.m., when his business closed. He stated that he was winning most of the time and that his earnings would average $300.00 - $400.00 per day. Generally he received his winnings in cash but occasionally he was paid by cheque.
[8] He testified that sometimes his winnings would be greater than $300.00 - $400.00, and sometimes, less but that he did not keep track of these winnings or of his occasional losses. He described himself as a casual drinker and that most players at a table would be drinking socially. At several different casino locations, the individuals who were gambling brought their own food and liquor, while at other locations they gave money to the dealer to purchase food and liquor at an outside restaurant.
[9] The Appellant's evidence was that he was winning much more frequently than he was losing at the game. He stated he used his winnings to pay his business and personal debts. He frequented the casinos to have fun, meet different people and drink with these people.
[10] While Mr. Epel's gambling efforts proved fruitful, his business endeavours were not as successful. The business revenue during these years fluctuated from a high, before expenses, of $96,000.00 in 1992 to a low of $39,500.00 in 1994.
[11] After completion of the audit by CCRA, Mr. Epel was informed he owed money and he changed bookkeepers and hired Gary Phomin, an accountant.
[12] During Mr. Epel's testimony, he indicated possible other sources of revenue during these periods, in addition to the winnings from the gambling activities. These included money from the sale of his condominium in Russia, money received from family members upon their arrival in Canada, repayment of a loan from a Mr. Vladimir Baker and settlement funds from a car accident. These other sources of non-taxable income became an issue during the hearing when Respondent counsel advised me that he was not able to review these particular sources at discovery proceedings as the notice of appeal disclosed gambling as the sole issue. Respondent counsel requested and received an adjournment to conduct further discovery in respect to these potential additional sources. Appellant counsel made it clear that he was not attempting to rely on exact dollar amounts from those other sources to "whittle down" the net worth assessment but simply to show that the Appellant received other unaccounted for revenue, in addition to gambling wins.
[13] On cross-examination, the Appellant testified that during the audit he was positive that he advised the auditor that he gambled and made a little money. He stated that his wins in gambling one year were about $20,000.00 but he was never sure how much he made, as he paid his bills with his winnings. He was unsure whether he told the auditor about all other sources of non-taxable income, which he claimed he received in those years. He stated that he received the money from his family in cash when they came into Canada, as cheques were not used in Russia. An account was opened jointly with his father and another account with his mother, prior to their arrival in Canada. When questioned about his loan to Vladimir Baker, the Appellant testified that he had known Baker's family for 45 years and that he made the loan to him in 1987 while visiting Russia. It was loaned in rubles but repaid in U.S. currency. Beyond that he was unsure of the original amount of the loan and stated that the repayment amount might have been $5,000.00 U.S. or $6,000.00 to $7,000.00 U.S. There was evidence in the bank statements (Exhibit R-2) of an amount deposited to the Appellant's account about the time of the car accident, although the amount is several thousand dollars less than the Appellant stated that he received.
[14] Diana Livshits and John Turmel both gave evidence on behalf of the Appellant. Ms. Livshits testified that her family has known the Appellant for approximately 20 years, as he is well known throughout the Russian community. She frequented the same casinos operated by John Turmel and it was there that she saw the Appellant throughout the years in question. She generally attended the casinos two to three times per week with her husband. She stated that she saw Mr. Epel at the casinos almost every time she was there and that he played poker. She recalled that her husband was paid primarily in cash, which confirmed the Appellant's evidence with respect to his winnings. She recalled Mr. Epel winning as he "... can be quite loud" referring to those times when he won.
[15] On cross-examination Ms. Livshits gave conflicting evidence to that of the Appellant and Turmel in respect to the various casino locations and the dates when they opened and closed.
[16] John Turmel gave evidence that he was in the business of earning his income through his gambling activities. Although he is an engineer, he referred to himself as a professional gambler, as his wins are taxed.
[17] In his last university year in engineering, he took a course in gambling. When he realized he had a knack for this and could make more money than in the engineering field, he decided to become a professional gambler and according to his evidence completed an honours thesis in gambling. He claimed that seven courts have accepted him as a gambling expert and that he is affectionately referred to in gambling circles as the "Taj Mahal" of gambling. He therefore never expected someone with Epel's background, who could neither read nor write, to "keep up with me". Turmel, who has gambled since 1974, stated that Epel was one of the toughest players he has ever played against. He explained that Epel was very lucky at gambling for a few years and that this accounted for his many wins. Now that luck has abandoned him, Epel no longer gambles.
[18] Turmel opened his first casino in the late 1970's. His evidence was that he was raided on a regular basis. He opened a casino in Hull in 1991. The authorities closed it several months later. After spending one month in jail, he re-opened another gambling establishment out of his home in Nepean. Subsequently he operated out of a number of different premises in the Ottawa area, at least one of which was eventually closed by authorities.
[19] Turmel's first recollection of the Appellant was in late 1991. He recalled the timing as it was shortly after his first release from jail for operating a gambling establishment. Turmel stated that his first impression of the Appellant was that he was a Russian peasant who would be "easy prey". After one month however the Appellant gained the dubious distinction of being one of the top five players in the Ottawa area. He testified that he played Epel for hundreds of hours and that he should have quickly broken Epel but was unable to do so. He described playing inexperienced players or "newbes" as "wonderful" compared to the more experienced players. However the Appellant, although inexperienced, did not fit into this category. He described the Appellant as a "fixture" in the establishments. Turmel stated that he could not remember a night that Mr. Epel was not there and more often than not he was winning. In a good week he testified that Epel could very easily take home $4,000.00. However Turmel did describe this as a one-time event and that once Epel's luck ran out, he would never be that lucky again. Turmel did state that he served only food and never liquor at his casinos. He did not recall if he allowed his patrons to bring their own liquor, as Epel had stated. According to his evidence, most winnings were paid in cash but cheques were used occasionally when there was insufficient cash.
[20] The Respondent called one witness, Mike Murray, who has worked for CCRA since 1990 and employed as a technical advisor for underground economy audits since 1993. When he commenced work on the Epel file, he was special auditor in the investigative division. Prior to his receipt of the file, another auditor had interviewed the Appellant in October 1997 and this first interview was limited to the shoe repair business. He did not believe that the question of gambling winnings had been put to Epel. After receipt of the file, he met with and interviewed Epel in June 1998. Tab 17, Exhibit R-1 contained an undated questionnaire. At page 7, the Appellant was asked: "Any non-taxable sources of funds? ... inheritances/lottery winnings/gifts/gambling". The auditor's handwritten note as to Epel's response was: "No". Murray stated that he would have read this question to the Appellant. He testified that if the Appellant had indicated that he had earned a little money from gambling, as Epel has stated, he would have attempted to further quantify the amount. On cross-examination, Murray stated that his practice would have been to provide an example of a non-taxable source of funds when asking the question contained in the questionnaire. However he did not specifically recall how he handled this question with Epel except to state, "I believe I would have". (given Epel an example of a non-taxable source) Murray testified that the first five pages of the questionnaire were not completed because he thought this information was obtained by the other auditor in the first interview. At page 9 of this document, Epel was asked the following question: "Have you received any money from family/friends, etc.? (Obtain details)". Murray's handwritten note as to Epel's response was: no paperwork, 6-7 years - gave $10,000.00 - $12,000.00, doesn't remember when went into bank to pay debts, brother in Russia visits. Murray's testimony was that Epel's brother had visited from Russia and that Epel stated he gave him this money six to seven years ago but that Epel gave no further information at the interview in respect to any other loans or money received.
[21] In June of 1999, Murray made handwritten notes (Exhibit R-1, Tab 16) respecting his conversation with Gary Phomin, Epel's then accountant. Murray stated that this was the first time that income, from gambling wins, was mentioned. In addition to extensive gambling wins, this note also indicates that Mr. Phomin notified the auditor that additional non-taxable funds came from Russia through the Appellant's niece in Toronto, together with additional cash received from loan repayments.
Appellant's Position:
[22] According to the Appellant's argument, Epel received windfall gains from his gambling activities as a casual poker player at various establishments operated by John Turmel in Hull and Ottawa during the periods in question. The increases between the Appellant's net worth and reported income were largely attributable to these non-taxable gains from casual gambling, together (but to a lesser extent) with other non-taxable sources of funds, such as repayment of loans, gifts from family and car insurance proceeds. Therefore the Minister's net worth calculations were not accurate.
Respondent's Position:
[23] The Appellant understated his income in the taxation years 1992, 1993, 1994 and 1995 by $71,351.00, $70,817.00, $56,713.00 and $58,481.00 respectively, which amounts were calculated using a net worth assessment. Penalties were properly imposed. As no returns were filed for 1996, 1997 and 1998, the Minister was correct in assessing, on an arbitrary basis, the Appellant's taxable income at $50,000.00 in each of these years. The Appellant was not involved in gambling to the extent claimed by the Appellant and his gambling activities cannot account for the amount of income determined by the net worth audit. If the Court does accept that gambling did account for some of his income, it cannot entirely explain the discrepancies. In addition documentation and other evidence of monetary gifts, loan repayments and car accident proceeds were insufficient to account for other non-taxable sources in addition to the gambling.
Analysis:
[24] The Appellant claims that the difference between the net worth assessment and the reported income is largely a result of gains from casual gambling. Casual gambling gains are not a source of income under section 3 of the Income Tax Act. A net worth assessment is a last resort method when there is no reasonably alternative way to establish an assessment. Associate Chief Justice Bowman in the case of Bigayan v. Canada, [1999] T.C.J. No. 778 at page 1 describes this method as follows:
[2] The net worth method, as observed in Ramey v. The Queen, 93 DTC 791, is a last resort to be used when all else fails. Frequently it is used when a taxpayer has failed to file income tax returns or has kept no records. It is a blunt instrument, accurate within a range of indeterminate magnitude. It is based on an assumption that if one subtracts a taxpayer's net worth at the beginning of a year from that at the end, adds the taxpayer's expenditures in the year, deletes non-taxable receipts and accretions to value of existing assets, the net result, less any amount declared by the taxpayer, must be attributable to unreported income earned in the year, unless the taxpayer can demonstrate otherwise. It is at best an unsatisfactory method, arbitrary and inaccurate but sometimes it is the only means of approximating the income of a taxpayer.
[25] When the Minister resorts to a net worth assessment, the assessment is presumed valid and the onus of proof falls on the Appellant to disprove the Minister's calculations (Pal v. Canada, [2002] T.C.J. No. 243 at page 2):
[11] The onus is on the Appellant to establish on a balance of probabilities that the Minister's calculations of income are wrong. The onus is one which is relatively easy to discharge where the Minister has relied on a net worth calculation because of the inherent imprecision of the method. However, there must be some credible evidence showing error in the result in order to discharge the onus.
And in Chomica v. Canada, [2003] T.C.J. No. 57 Associate Chief Justice Bowman summarizes how the onus works at paragraph 17, page 4 as follows:
[17] The fundamental rule in income tax appeals and that is that the taxpayer has the onus of demonstrating that the factual assumptions upon which the assessment is based are wrong or do not support the assessment. This rule is well settled and I need not repeat the usual authorities that are traditionally cited in support of it. However the standard of proof is a civil one and a prima facie case, if unrebutted, will entitle a taxpayer to succeed.
[26] The question is whether the Appellant has established sufficient evidence, on a balance of probabilities, to show that his net worth increase was largely from gambling wins as a poker player and to a lesser extent non-taxable sources, such as gifts and loans. If he is able to do that and establish that his monetary wins as a poker player were the result of casual gambling and not from the business of gambling, then the Appellant will have sufficiently rebutted the burden of proof which is initially upon him. If I characterize the Appellant's gambling habits as a business operation, then of course it could be difficult if not impossible to mathematically formulate in any meaningful way the exact amount of winnings. In most instances, the only record and best available record of gambling wins is in the memory of the player. It is therefore very difficult if not impossible to use such winnings to offset, on a dollar-by-dollar amount, the net worth calculations, which are themselves imprecise. In that event, the calculations pursuant to the net worth method will stand.
[27] The Appellant's evidence is that he gambled on a very regular basis throughout the years in question, and that he had substantial and consistent wins. According to the facts, these wins appear to be largely beginner's luck, which were sustained over a lengthy period of time rather than wins based on any type of system or background knowledge of the game as described by John Turmel. In fact Turmel in his evidence indicated that the Appellant was lucky for a number of years, but described this as a one-time occurrence. It is clear from Turmel's evidence that Epel was a regular player who consistently won, sometimes up to $4,000.00 weekly. But he made it clear that his winnings were not based on any type of system such as one that Turmel might use. Ms. Livshits also corroborated the evidence of the Appellant in respect to his very regular playing habits. Both of these witnesses corroborate Epel's testimony respecting his gambling habits and his wins. While some of the evidence was vague or inconsistent in respect to casino locations, dates of casino closings and openings and the exact dates of Epel's wins, I do not believe these discrepancies, on some of the more minor details, warrant that I ignore the evidence of the Appellant, where it is corroborated by two witnesses on the very crux of the gambling argument - his regular attendance as a player and his consistent wins. There is no evidence to contradict the Appellant and the other two witnesses.
[28] The Appellant testified that he did not attend movies or theatre productions unless they were in the Russian language, as his knowledge of English was not sufficient for him to enjoy these forms of entertainment. He therefore used gambling as his entertainment. It was a hobby from which he derived pleasure. He did not require adept language skills when sitting in a game of poker. Although his wins were substantial, the evidence supports that he did not view his gambling activities as anything akin to a business operation. The evidence does not disclose that he had any type of system or organization to his wins. For these years in question, his wins appear to simply be the "luck of the draw" and the excitement and pleasure of the wins kept him returning. In the Federal Court decision of Balanko v. M.N.R., [1988] F.C.J. No. 175 at page 2, Justice Collier concluded that:
There is no doubt the Defendant was, and apparently still is an inveterate gambler. That does not mean he was in the business of gambling.
He went on to state near the end of his decision at page 3:
There can be no doubt that the Appellant freely indulged his inordinate passion for gambling, but I cannot conclude that in doing so he carried on a business. Counsel for the Minister stressed that the Appellant gambled with a view to profit. However, it must be observed that such intention is one shared by all who gamble, and the presence of the intention to win or make money in gambling, which is there in all who gamble, does not lead to a conclusion that all who gamble, or even all those who gamble frequently, are carrying on a business.
Counsel for the Minister stressed that the Appellant took risks, and that he borrowed money in order to carry on his gambling activities. While risk-taking is necessary in a business, it is management or minimization of risk which is the characteristic of business activity.
[29] In the case of Luprypa v. Canada, [1997] T.C.J. No. 469 Justice McArthur set out at paragraph 13 the criteria necessary to determine whether an individual is engaged in a business of gambling. Those are:
a) He carefully managed the risks.
b) He was a skilled player.
c) He played Monday through to Friday each week.
d) He spent his afternoons playing snooker to perfect his skills.
e) He played inebriated opponents after 11:00 p.m. to minimize his risk.
f) He won most of the time earning, approximately $200.00 daily.
g) He drank alcoholic beverages only on weekends when not playing pool to give him a sober advantage over his inebriated opponents.
h) He was calculating and disciplined.
i) It was his primary source of income and he relied on this steady income.
[30] With respect to these nine items, Epel stated that he attended for the social enjoyment and that if he was losing, he simply left. He drank socially with other players. He did not manage his risk by identifying particularly inept players or inebriated players. There is no evidence to suggest that he attempted to arrange who his opponents would be so that he would have an advantage. He did not attempt to manage or minimize his risk through a calculated method or system. This distinguishes Epel, the habitual (and lucky) gambler, from someone like Turmel, the professional gambler. He was a lucky gambler but not one who worked to perfect his skills. He participated because he enjoyed the game and the social interaction. Turmel testified that he certainly was a quick learner, with a natural ability for the game, who for a time had luck on his side. However Epel was not a skilled player whose focus was to constantly develop and perfect his skills, as Turmel had done. His evidence was that he still considered his business operation to be the shoe repair business and not his gambling activities. The facts support that the Appellant was using his gambling as a form of social entertainment, with the added advantage that he had regular and substantial wins. There is certainly no evidence before me where I could find that he was in any way conducting his gambling activities as a professional calling. Turmel, at the other extreme, gave evidence of the courses he studied, the papers he wrote, the systems he established to win and the rake off portions in a game, in an attempt to develop an edge in predicting his percentage chance of winning any given game.
[31] In addition to the evidence respecting gambling, the Appellant produced evidence of other revenue that was received during this period, such as monetary gifts from his parents, repayment of a loan and settlement funds from a car accident. Appellant counsel argued that these amounts provided additional explanations for non-taxable sources of income during this period. While some of the evidence respecting these other sources was vague and in some areas lacking in supporting documentation, there was evidence that the Appellant did receive additional funds in this period. There was a $10,000.00 bank deposit in December of 1992, although a document (Exhibit A-2) apparently signed by the Appellant's mother confirmed a gift of a different amount of $11,000.00 U.S. in 1992. A document, (Exhibit A-3) from the Appellant's insurance broker, stated that Epel did receive settlement funds from a car accident in 1994, although it confirmed little as to the amount that Epel received. There was a bank deposit of $11,358.00 shortly after the accident. The main argument here revolves around the gambling issue. I accept the Appellant's argument that there is sufficient evidence to establish the existence of additional non-taxable sources of income during this period, with the primary source being the consistent and substantial windfall gains of Epel's gambling activities. Epel's evidence was that he did indicate to the auditor that he made money from gambling. The auditor's evidence was that Epel never indicated this during the interview and in fact when asked if he had other non-taxable sources of cash available to him, the Appellant answered no. It is clear that the Appellant has great difficulty with the English language. As I recall at one point he stated that he understood about 50%. In addition he is at a distinct disadvantage because he cannot read or write. I believe he would have great difficulty understanding an auditor's questions in an interview process. This may well have produced incomplete or incorrect responses to interview questions unless time was taken to fully explain what was being asked. As well, I note that a substantial portion (the first five pages of a 10-page questionnaire) was simply not completed. This document purported in the bottom left hand corner to be a "detailed initial interview". Taking into account Mr. Epel's education and language problems, I place very little reliance, if any at all, on a self-proclaimed "detailed initial interview" which is about 50% complete.
[32] The Appellant has satisfied the onus which is upon him by demonstrating, on a balance of probabilities, that the increase in cash during these periods was largely attributed to non-taxable windfall gains from casual gambling, together with other non-taxable sources of money. These sources of money do not fall under section 3 of the Act and are therefore not taxable. It follows that the GST reassessment with respect to sales of taxable supplies from September 1, 1991 to August 31, 1995 will be vacated and that the taxation years 1996 through to 1998 are to be assessed for income based on the returns as filed by the Appellant. Penalties are to be deleted.
[33] The appeals are allowed, with counsel having one set of costs.
Signed at Ottawa, Canada, this 20th day of October 2003.
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"Diane Campbell" |
Campbell, J.
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CITATION: |
2003TCC707 |
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COURT FILE NO.: |
2001-1769(IT)G and 2001-1771(GST)I |
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STYLE OF CAUSE: |
Anatoly Epel v. Her Majesty the Queen |
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PLACE OF HEARING |
Ottawa, Ontario |
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DATE OF HEARING |
November 28 and 29, 2002 June 19 and 20, 2003 |
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REASONS FOR JUDGMENT BY: |
The Honourable Justice Diane Campbell |
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DATE OF JUDGMENT |
October 20, 2003 |
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APPEARANCES: |
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Counsel for the Appellant: |
Gregory Sanders and Julie Abraham |
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Counsel for the Respondent: |
Charles M. Camirand
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COUNSEL OF RECORD: |
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For the Appellant: |
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Names: |
Gregory Sanders and Julie Abraham |
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Firm: |
Soloway, Wright Ottawa, Ontario |
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For the Respondent: |
Morris Rosenberg Deputy Attorney General of Canada Ottawa, Canada |