Section 244

Subsection 244(4) - Limitation period

Cases

PS&E Contractors Ltd. v. The Queen, 89 DTC 5067 (Sask. C.A.)

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The Queen v. Print Three, 88 DTC 6315 (Ont. Prov. Ct.)

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R. v. Les Habitations Perigord Inc., 88 DTC 6267, [1988] 2 CTC 64 (Que. C.A.)

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Re Pica and The Queen, 85 DTC 5041, [1985] 1 CTC 73 (S.C.O.)

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James v. The Queen, 84 DTC 6570, [1984] CTC 672 (S.C.O.), rev'd by 86 DTC 6432, [1986] 2 CTC 288 (Ont CA), briefly aff'd by 88 DTC 6273, [1988] 2 CTC 1, [1988] 1 S.C.R. 669

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R. v. Simmons, 84 DTC 6171 (Nfld. Prov. Ct.)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(2) 58

Fee et al. v. Bradshaw et al., 82 DTC 6264, [1982] CTC 201, [1982] 1 S.C.R. 607

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Usarco Ltd. v. A.G. Canada, 80 DTC 6308, [1980] CTC 484 (FCTD)

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Medicine Hat Greenhouse Ltd. and German v. R., 79 DTC 5091, [1980] CTC 114 (Alta. C.A.)

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Subsection 244(5) - Proof of service by mail

See Also

DaSilva v. The Queen, 2018 TCC 74 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 335 - Subsection 335(6) failure of official to confirm that the notice of assessment was included in a batch that had been accurately processed 300
Tax Topics - Excise Tax Act - Section 303 - Subsection 303(7) - Paragraph 303(7)(a) taxpayer's testimony that she had not received a notice of assessment was credible 162
Tax Topics - Income Tax Act - Section 166.1 - Subsection 166.1(7) - Paragraph 166.1(7)(a) testimony accepted that notice of assessment had not been received 89

Hamer v. The Queen, 2014 DTC 1168 [at 3602], 2014 TCC 218

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Skalbania v. The Queen, 2009 DTC 2066, 2009 TCC 576

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Subsection 244(7) - Proof of failure to comply

Cases

Cholodniuk v. R., 92 DTC 6168 (Sask. C.A.)

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A.G. (Canada) v. Romeo's Trucking Ltd., 80 DTC 6238, [1980] CTC 278 (Sask. D.C.)

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Subsection 244(9) - Proof of documents

Cases

Aztec Industries Inc. v. The Queen, 95 DTC 5235 (FCA)

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Subsection 244(10) - Proof of no appeal

See Also

Sicoli v. The Queen, 2013 DTC 1167 [at 917], 2013 TCC 207

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Poulin v. The Queen, 2013 DTC 1102 [at 545], 2013 TCC 104

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 149

Carcone v. The Queen, 2012 DTC 1032 [at 2651], 2011 TCC 550

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Graham v. The Queen, 92 DTC 1012 (TCC)

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Subsection 244(13) - Proof of documents

Cases

The Queen v. Ehli, 99 DTC 6505 (Alta CA)

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Swyryda v. The Queen, 81 DTC 5109 (Sask QB)

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Israel v. The Queen, 79 DTC 5418, [1979] CTC 468 (FCTD)

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Subsection 244(14) - Mailing or sending date

See Also

236130 British Columbia Ltd. v. The Queen, 2006 DTC 2053, 2005 TCC 770

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VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732

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McIntyre v. MNR, 93 DTC 999 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(2) 114

Everett's Truck Stop Ltd. v. The Queen, 93 DTC 965 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) inducemnt to purchase product for more 92

Subsection 244(15) - Date when assessment made

Cases

Skalbania v. The Queen, 2009 DTC 2066, 2009 TCC 576

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McGowan v. The Queen, 95 D.T.C 5337 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 166.2 - Subsection 166.2(1) 40

Subsection 244(16)

See Also

Aubrey Dan Family Trust v. Minister of Finance, 2016 ONSC 3801, aff'd 2017 ONCA 875

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Ontario - Taxation Act 2007 - Section 158 federal form with CRA insignia purported to be a prescribed form 328
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) original assessment not dealing with Ontario tax starts the normal Ontario reassessment period 281

Subsection 244(20)

See Also

Menzies v. The Queen, 2016 TCC 73 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.6) receipt of notice of redetermination of loss by limited partner not relevant 148

Administrative Policy

18 October 2016 Internal T.I. 2016-0640321I7 - Subsections 152(1.5) and 244(20)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.5) requirement satisfied by delivery to partnership address 25