VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732, aff'd 2005 DTC 5095, 2005 FCA 36 -- summary under Paragraph 152(4)(b)

A notice of reassessment was given by CCRA to a courier before the taxpayer became statute-barred, but was not received by the taxpayer until after the expiration of that period. Woods J. noted that an assessment is made when notice has been sent by the Minister, and found that this requirement had been satisfied when the assessment was picked up by the courier as it was at that point that it had left the Minister's possession for transmission to the taxpayer.