Pratte, J.:—We do not need to hear you, Mr. Vita.
This appeal raises but one issue: did the Minister of National Revenue satisfy the requirements of subsection 152(2) of the Income Tax Act when, on March 16, 1979,* he sent to the late William R. Stephens notices of reassessment having, on the left-hand corner, the words “Revenue Canada Taxation” (instead of Department of National Revenue — Taxation) and, at the bottom, the printed signature of a former Deputy Minister followed by the words “Deputy Minister of National Revenue for Taxation”?
Subsection 152(2) requires the Minister to “send a notice of assessment” to the taxpayer. Nowhere in the Act do we find prescriptions relating to the form of that notice. It follows, in our view, that the form of the notice does not matter and that the subsection merely requires that the notice be expressed in terms that will clearly make the taxpayer aware of the assessment made by the Minister. The notices here in question clearly met that requirement. First, the fact that they bore the printed signature of a person who had ceased to be the Deputy Minister was of no consequence since nothing in the statute requires that notices of assessment be signed by anyone. Second, the fact that the words “Revenue Canada” were not the legal designation of the Department of National Revenue was also immaterial since, as was decided by the judge below, the use of that “publicly well known appellation” could in no way mislead the taxpayer “into thinking that these forms did not emanate from the Department of National Revenue.”
The appeal will, for these reasons, be dismissed with costs.
Appeal dismissed.
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