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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