In finding that the reference in s. 146(8.2)(c)(ii) to the year in which a notice of assessment is sent refers to the notice of assessment under Part I, the Directorate stated:
[U]nless otherwise specified in the Act, it is our view that where a provision of Part I of the Act refers to a notice of assessment, that provision necessarily refers to a notice of assessment under Part I of the Act and not to a notice of assessment under any other part of the Act.