Subsection 195(2) - Corporation to make payment on account of tax
Optical Recording Corp. v. The Queen, 86 DTC 6465,  2 CTC 454,  2 CTC 325, 86 DTC 6569 (FCTD), aff'd 87 DTC 5248,  1 CTC 417
It was illegal for Revenue Canada to adopt a policy of not requiring taxpayers to make the payment required by s. 195(2) on the last day of the following month.
|Locations of other summaries||Wordcount|
|Tax Topics - General Concepts - Estoppel||103|
|Tax Topics - Income Tax Act - Section 152 - Subsection 152(4)||notice of assessment that did not assess tax that was yet due was a nullity||187|
WTC Western Technologies Corp. v. MNR, 86 DTC 6027,  1 CTC 110 (FCTD)
An assessment may not be issued under s. 195(2) at a time before the time that the taxpayer is required to file a return.
Subsection 195(5) - Evasion of tax
86 C.R. - Q.35
There are no set guidelines re due diligence test.