15 May 1990 Ruling 90065001 F - Time Limit for Assessment

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

19(1)

I am writing in response to your letter of February 23, 1990, concerning the tax affairs of your client, 19(1).  I apologize for the delay of my response.

While I can appreciate 19(1)  position, the Income Tax Act is very specific with regard to the time limit for assessments and provides no discretion on properly assessed returns.  However, I would mention that in certain circumstances relief may be granted under the provisions of the Financial Administration Act.  Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office.  It is then followed by a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria.  I would mention that this process may take some time before the decision is made.

Ms. Esta Mikhail, a departmental officer, is handling your client's file.  You may wish to contact Ms. Mikhail directly to discuss this matter.  Ms. Mikhail may be contacted by telephoning (613) 952-3606 or by writing to the Publications Division, Technical Review Section, Revenue Canada, Taxation, 875 Heron Road, Ottawa, Ontario K1A 0L8.

I wish to thank you for bringing your concerns to my attention. I wish to assure you that 19(1) will receive the utmost consideration possible in her case.

Yours sincerely,

Otto Jelinek

EM/clApril 12, 1990Esta Mikhail - 952-3606

MD/jp(90065001)40May 9, 1990D.M.'s Office

Stall Not Required19(1)