Siam v. Canada
The Tax Court did not err: appellant failed to prove the 2018 notice of assessment was not mailed, the normal assessment period therefore ended by April 19, 2021, the 2023 reassessment fell within s.152(4.2) and was not subject to objection under s.165(1.2), and any CRA misstatements could not create a substantive right to object; appeal dismissed.
Source excerpt
- Reassessment
- Notice of assessment
- Limitation period
- Legitimate expectations
- Credibility and standard of review