CRA will not open up statute-barred years to apply a subsequent favourable judicial development
3 March 2014 - 11:10am
CRA will not accede to a request to open up a statute-barred year to reassess based on a favourable decision involving another taxpayer (here, apparently, Craig on farming losses). This accords with Abraham.
Neal Armstrong. Summary of 10 January 2014 Correspondence 2013-0513401M4 F under s. 152(4.2).