FEB 19 1988
Attention: Mr. Ernest Noel de Tilly Director
From: Small Business and General Division R. Lange 957-2138
RE: XXXX Remission of Penalty on Unpaid Taxes
Attached is a self-explanatory memorandum dated November 20, 1987, from the Saint John District Office, Appeals Division, in respect of a reassessment of the above-captioned corporation. The reassessment was based in part upon our memorandum of July 15, 1986, to the District Office, a copy of which is enclosed with related materials for your consideration.
Inasmuch as this matter is currently under Notice of Objection, it is our understanding that the appropriate procedure, in the circumstances, is for Appeals and Referrals Division to resolve the issues raised.
We would, however, take this opportunity to confirm our earlier opinion as referenced above. We note that the taxpayer has not submitted any new facts, generally accepted accounting principles or relevant law which address the deductibility of the amounts included on the T2S(1) form which is at issue.
ORIGINAL SIGNED BY XXXX Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch