Bonner,
T.C.J.:—The
appellant
appeals
from
assessments
of
income
tax
for
the
taxation
years
1980
to
1985,
inclusive.
The
appellant
failed
until
1986
to
file
returns
of
income
for
any
of
those
taxation
years.
Tax
was
payable
for
each
of
those
years
with
the
result
that
returns
were
required
by
virtue
of
the
provisions
of
subsection
150(1)
of
the
Income
Tax
Act
("Act").
Accordingly
the
respondent
assessed
penalties
under
subsection
162(1)
of
the
Act
with
respect
to
the
years
1980
to
1984,
both
inclusive.
The
return
for
the
1985
taxation
year
was
filed
on
time.
The
appellant's
complaint
appears
to
be
that
he
should
not
be
held
liable
to
penalties
and
to
law
costs.
The
latter,
I
assume,
arose
as
a
result
of
the
collection
process.
His
reasoning
is
that
the
respondent
was
in
full
possession
of
all
the
facts
relating
to
his
income.
That
income
came
from
two
sources:
(a)
the
appellant's
employment
at
International
Nickel
Company
and
(b)
interest
on
Canada
Savings
Bonds.
The
appellant
argues
that
Revenue
Canada
had
reports
of
all
such
income
because
the
Bank
of
Canada
had
his
social
insurance
number
in
connection
with
the
bonds
and
International
Nickel
Company,
the
employer,
had
his
social
insurance
number
on
a
TD1
form.
Further,
so
the
appellant's
reasoning
went,
the
employer
had
the
appellant's
current
address
on
its
personnel
records
and
the
respondent
was
thus
in
a
position
to
seek
him
out
at
any
time.
Thus,
so
the
appellant
proceeded,
T1
returns
of
income,
which
the
appellant
said
he
found
impossible
to
fill
out
in
any
event,
were
not
really
needed
and
the
penalties
and
law
costs
were
therefore
unjustified.
The
appellant
seems
to
be
convinced
that
it
was
entirely
the
respondent's
fault
that
he
had
not
been
located
and
that
his
tax
indebtedness
had
not
been
brought
to
his
attention
sooner.
In
short
the
premise
underlying
the
appellant's
argument
is
that
returns
of
income
are
unnecessary
in
cases
where
the
Minister
is
in
possession
of
or
in
a
position
to
secure
those
facts
which
are
required
to
assess
tax.
The
short
answer
to
this
argument
is
that
subsection
150(1)
required
that
returns
of
income
be
filed
in
the
circumstances
of
this
case.
Thus
it
has
not
been
shown
that
the
late
filing
penalties
for
the
1980
to
1984
taxation
years
were
improperly
imposed.
There
is
no
basis
on
which
fault
can
be
found
with
the
1985
assessment.
The
appeals
will
therefore
be
dismissed.
Appeals
dismissed.
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