| May 17, 1990 | |
| L.C. Tremblay | Technical Review Section |
| A/Director | S. Parnanzone |
| Appeals and Referrals Division | Tel. (613) 957-9232 |
Subject: 19(1) Settlement Offer STALLED
We are forwarding the ministerial correspondence file (yellow docket) for consideration and reply by your office since it involves a settlement offer for the taxpayer's outstanding appeal to the Tax Court of Canada.
24(1)
As regards 19(1) remission request itself, it cannot be dealt with at this time because of the outstanding appeal. Generally, tax remission is a procedure of last resort, not an alternative procedure to the normal channels, such as the appeal process, for the solution of tax problems.
Bernhard BuetowChiefTechnical Review SectionTechnical Publications Division