24(1) 903627
O. Laurikainen
(613) 957-2129
19(1)Feb 25, 1991
Dear Sirs:
Re: Request for Technical Interpretation
This letter is to confirm our February 11, 1991 telephone conversation wherein we advised you that we are unable to respond to your request for a technical interpretation dated December 12, 1990. It is the general policy of the Rulings Directorate not to issue interpretations to taxpayers on issues directly related to completed transactions or cases where the taxpayer is involved in discussions with a particular District Taxation Office or Taxation Centre.
Since you are involved with the filing of a notice of objection with the Sudbury Taxation Centre our Division must respect the independence of the objections and appeals process and we cannot be involved with providing opinions on cases under objection or appeal unless requested to do so by Head Office Appeals Branch. In our view, there is nothing to prevent a District Taxation Office or Taxation Centre from referring a case to the Head Office Appeals Branch for their consideration in accordance with paragraph 14 of Information Circular 80-7 dated June 30, 1980. However this is a matter to be determined by the Chief of appeals of the appropriate District Taxation Office or Taxation Centre.
We trust this adequately explains our position.
Yours truly,
for Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
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