Subsection 225.2(2) - Authorization to proceed forthwith
Cases
MNR v. Rouleau, 95 DTC 5597, [1995] 2 CTC 442 (FCTD)
The fact that the taxpayer was discovered to have approximately $213,000 in cash stored in his apartment, in a safety deposit box and in a cold...
The Queen v. Golbeck, 90 DTC 6575, [1990] 2 CTC 438 (FCA)
In setting aside an order of the trial judge, Marceau J.A. found that where, on the basis of the material put before the Court, it appears that...
The Queen v. Satellite Earth Station Technology Inc., 89 DTC 5506, [1989] 2 CTC 291 (FCTD)
The taxpayer was able to raise a reasonable doubt on a review application under s. 225.2(8) that the Crown's collection process would in fact be...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 225.2 - Subsection 225.2(8) | 87 |
Dep. MNR v. Atchison, 89 DTC 5088 (BCSC)
The taxpayer's application to have an ex parte order set aside was allowed in light of the absence of evidence that delay would jeopardize...
Chudina v. Deputy Attorney General of Canada, 88 DTC 6043, [1988] 1 CTC 303 (BCSC)
On December 17, 1986, the Minister assessed the taxpayer, mailed the assessment and a demand for payment, obtained a judgment under s. 223(2) and...
Minshull v. M.N.R., 87 DTC 5385, [1987] 2 CTC 223 (Sask QB)
Applications under s. 225.2(2) to vacate s. 225.2(1) directions were dismissed. "The only reasonable conclusion to be drawn from the...
1853-9049 Quebec Inc. v. The Queen, 87 DTC 5093, [1987] 1 CTC 137, 87 DTC 5031, [1986] 2 CTC 486 (FCTD)
The Minister was unable to establish on balance of probabilities that failure to act under s. 225.2 would result in the taxpayer wasting,...
Danielson v. Dep. A.G. of Can., 86 DTC 6518, [1986] 2 CTC 341, [1986] 2 CTC 380 (FCTD)
The issue under s. 225.2(1) "is not whether the collection per se is in jeopardy but rather whether the actual jeopardy arises from the likely...
Laframboise v. The Queen, 86 DTC 6396, [1986] 2 CTC 274 (FCTD)
Various actions of the taxpayer, who had been charged with a drug trafficking offence, such as being apprehended transporting $14,000 in cash...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 226.2 | 16 |
Subsection 225.2(8) - Review of authorization
Cases
The Queen v. Satellite Earth Station Technology Inc., 89 DTC 5506, [1989] 2 CTC 291 (FCTD)
"When the evidence submitted by the taxpayer applicant raises reasonable doubt about the sufficiency of evidence originally provided by the Crown...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 225.2 - Subsection 225.2(2) | 69 |
Subsection 225.2(9) - Limitation period for review application
Cases
McCall v. The Queen, 88 DTC 6466, [1989] 1 CTC 383, 89 DTC 5148, [1988] 2 CTC 309 (FCTD)
A taxpayer cannot proceed on a motion pursuant to s. 225.2(2) until the Minister has made a jeopardy determin