Bowman,
J.T.C.C.:—This
appeal,
from
an
assessment
for
the
appellant’s
1985
taxation
year
has
to
do,
if
I
understand
the
appellant's
position
correctly,
with
the
assessment
of
interest.
When
the
matter
originally
came
on
for
hearing
on
July
19,
1993
I
adjourned
it
to
give
the
parties
an
opportunity
of
meeting
to
sort
out
the
complex
interest
computations
with
which
the
appellant
takes
issue,
and,
if
possible,
of
settling
the
matter.
Meetings
were
held,
but
no
resolution
of
the
issues
was
reached
and
the
case
was
reconvened
in
Vancouver
on
February
17,
1994.
Mr.
Patton
contended
that
the
interest
charged
was
excessive,
partly
because,
as
he
alleges,
he
had
paid
the
tax
previously
and
partly
because
of
certain
delays
on
the
part
of
the
Department
of
National
Revenue
in
the
reassessment
of
his
company
which
he
says
resulted
in
his
not
being
able
to
apply
a
refund
made
to
his
company
against
his
own
tax
liability
as
early
as
he
might
have.
A
number
of
detailed
schedules
were
introduced
into
evidence
by
the
respondent
setting
out
the
statements
of
account
of
Mr.
Patton
in
respect
of
assessments
for
years
back
to
1980.
Also,
an
appeals
assessor,
Mr.
Guy
Louie,
gave
evidence
explaining
the
calculations.
I
have,
to
the
best
of
my
very
limited
knowledge
of
accounting,
endeavoured
to
analyze
these
calculations,
but
I
have
been
unable
to
find
any
error
in
the
statements.
I
can
understand
and
sympathize
with
the
plight
of
any
taxpayer
who
embarks
on
the
daunting
task
of
challenging
the
Department
of
National
Revenue’s
calculations
of
interest.
Nothing,
however,
in
the
evidence
established
that
credits
were
not
appropriately
made
or
that
interest
was
incorrectly
charged
at
the
prevailing
rate
on
arrears
of
tax.
It
appears
that
a
cheque
for
$64,439.66
was
mailed
to
Mr.
Patton’s
company,
Canadian
Motors
Ltd.,
on
November
24,
1986
and,
on
March
2,
1987
this
amount
was
credited
to
his
account
as
of
November
24,
1986.
On
June
18,
1987
he
was
reassessed
for
1985
and
on
July
2,
1987
a
refund
of
$2,935.80
was
issued
to
Mr.
Patton.
After
that
assessment
for
1985
he
was
reassessed
three
more
times
for
1985
—
on
May
24,
1989,
February
12,1991
and
December
23,
1992.
It
does
not
appear,
however,
that
the
interest
ultimately
charged
against
him
necessarily
relates
solely
to
the
1985
taxation
year.
Rather,
it
appears
to
be
a
cumulative
total
arising
from
all
years
prior
and
subsequent
to
1985.
As
stated,
it
is
a
difficult
task
for
a
person
without
a
knowledge
of
accounting
to
challenge
the
interest
calculations
of
the
Department
of
National
Revenue.
Had
Mr.
Patton
wished
to
question
specific
items
it
would
have
been
helpful
if
he
had
called
a
chartered
accountant
to
show
where
the
Department's
calculations
were
wrong.
In
the
circumstances,
I
have
no
basis
upon
which
I
can
conclude
that
the
assessment
of
interest
is
wrong
and
I
must
therefore
dismiss
the
appeal.
Appeal
dismissed.
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