The appellant was assessed for 12 reporting periods pursuant to a document whose first page was a summary of the aggregate results of the assessment. Sommerfeldt J noted (at para. 36):
Subsection 300(2) suggests that, even though there might be only one notice of assessment, if multiple reporting periods are covered by that notice, it is appropriate for the Minister, in that notice, to issue multiple assessments (presumably, a separate assessment for each reporting period).
He further indicated that although “section 306 implies that there is to be a separate appeal for each assessment or reassessments” (para. 38), Rule 25 contemplated that “if a person desires to appeal in respect of more than one assessment or reassessment under the ETA, the person may join the various appeals and their respective assessments in a single notice of appeal” (para. 39). However, in light of ETA s. 309(1) (para. 40):
[W]here more than one assessment is joined in a notice of appeal, the assessments, throughout the judicial process in this Court, retain their separate identities as individual assessments for specific reporting periods.
Accordingly, the appeal before him was of 12 assessments.