| June 14, 1989 | |
| TORONTO DISTRICT OFFICE | Specialty Rulings |
| Directorate | |
| G. Cappella | G. Thornley |
| Audit Review - Business Enquiries Group | (613) 957-2101 |
| File No. 7-3947 |
Subject: 19(1)
We are returning your opinion request dated May 24, 1989 regarding the 19(1) as it is incomplete.
No documents or exhibits were enclosed with the enquiry nor were specific technical questions raised to which we could address our review.
Before you resubmit your opinion request to this office with the various documents attached, be sure that the relevant facts in the documents are included in your statement of facts. They should also be accompanied by your analysis of their bearing on the issue or issues. In addition, you should set out the specific sections of the Act that are relevant to your proposed reassessments and which provisions of the Act you feel are being or have been abused. In particular we would like to know for which provisions of the Act or Regulations you require a Technical Interpretation.
You may decide, after reviewing your submission as revised, amended and clarified,m that the issues involved are more appropriately within the purview of Head Office Audit Applications.
We trust our comments are helpful.
for Director Small Business and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch
Enclosed