23 October 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656948
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [NV91_275 - SE91_209.211]/OC91_074 — Penalty in Connection with Collection Procedure"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-10-23 08:00:00",
"field_tags": []
}
Main text

October 23, 1991

Collections Division                    Business and Central
J.B. Larouche                             Division
Director                                R.B. Day
                                        (613) 957-2136
                                        912346

Application of 239(1(d) & 162(7)(b) to 159(2) & (3)

Further to our telephone conversation of October 18, 1991, with Mr. A. Prosia, we are forwarding for your consideration and reply the August 15, 199], letter from the law firm of 24(1) oncerning the possible application of the above noted penalty provisions to situations where an individual fails to copy with the requirements of 159(2) and thus becomes liable under 159(3).

We examined our research files and found that the possibility of applying these penalty provisions in 159(2) & (3) situations had never been addressed by this Directorate. During our conversation with Mr. Prosia, he indicated that to the best of his knowledge, the above noted penalty provisions are not given consideration in connection with the collection procedures instituted as a result of the application of 159(3).

Could you please advise    19(1)     of your views on this matter.

Should you require our views on the technical aspects of this enquiry please contact the writer.

We telephoned 19(1) to advise him of the transfer of his letter to your Division.

B.W. Dath Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch

000074