Manfred Hoefler v. Minister of National Revenue, [1989] 1 CTC 2299, 89 DTC 190 -- text
Christie, A.C.J.T.C.: —The issue is whether the appellant is liable to a penalty of $4,088.95 in respect of his 1983 taxation year. The notice of appeal is dated May 26, 1987 and is signed by him. It reads: