Estoppel

a taxpayer received dividends for s. 160 purposes where she was estopped from arguing otherwise or because the corporate insolvency did not matter

issue estoppel precluded reviewing compellability of documents from a Saskatchewan regulatory authority

CRA not estopped from applying a different valuation method from that used in previous audits

Minister not precluded from reassessing contrary to initial acceptance of non-residency in returns as filed

errant advice of a CRA official does not change Act’s application

limited estoppel remedies in Quebec/no abusive conduct by CRA

Estoppel should apply to appeal in respect of prior criminal tax evasion conviction as quantum requirements were met