The Queen v. Canadian Marconi Co., 91 DTC 5626 (FCA)
After quoting the definition, Mahoney J.A. stated (p. 5629):
"That definitional section cannot, in my view, prevail to render the terms assessment and reassessment entirely interchangeable in a provision that clearly distinguishes between them and expressly provides differently in respect of them. In my opinion, subsection 152(4) is such a provision."
Cormier v. The Queen, 91 DTC 5159 (FCTD)
S.225.1(3), which was added applicable to "notices of assessment" mailed after 1984, did not apply where a reassessment was issued in 1983, and a notice of confirmation issued in 1984. Because a notice of confirmation does not effect any change to an assessment, it is not itself an assessment.
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|Tax Topics - Income Tax Act - Section 225.1 - Subsection 225.1(3)||46|