Canada v. Zelinski, 2000 DTC 6001 (FCA) -- summary under Subsection 161(1)

The Court rejected the submission of the taxpayer that given that s. 158(8) deemed an assessment to be valid and binding until the time of the reassessment interest under s. 161(1) arising because of the reassessment of a taxpayer accrued only from the time of the reassessment rather than from the time the taxpayer filed his return. Sexton J.A. noted (at p. 6010) that "outstanding" was broadly defined as '''that stands over; that remains undetermined, unsettled or unpaid'" and that "simply put, taxes that a taxpayer underestimates from his or her tax return are unpaid and are therefore outstanding, regardless of the date in which the Minister reassesses ... ."