| May 30, 1990 | |
| TORONTO DISTRICT OFFICE | Business and General |
| Appeals Division | Division |
| Bill Guglich | |
| Dennis Jenkinson | (613) 957-2102 |
| File No. 900228 |
Subject: 19(1)
This is in reply to your round trip memorandum dated March 21, 1990 concerning 24(1)
We had the opportunity previously, to review a similar situation involving the case of 19(1) . For your information a copy of our November 21, 1988 memorandum to G.R. Mohr, Director, Mississauga District Taxation Office, is enclosed. We are not aware of any subsequent changes respecting the Department's position.
We trust this will be of assistance to you.
for Director Business and General Division Specialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch