14 March 2011 External T.I. 2010-0390311E5 - Section 159 of the Income Tax Act -- summary under Subsection 159(2)

Where a taxpayer dies with a tax debt larger than the value of his estate, the administrator would be at risk of an assessment under s. 159(3) if he paid for the services to the estate of an accountant without first obtaining a clearance certificate.