VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732, aff'd 2005 DTC 5095, 2005 FCA 36 -- summary under Subsection 244(14)

After finding that an assessment of the taxpayer had been made when the assessment was picked up by a courier for delivery, Woods J. went on to indicate that he did not wish to decide on a submission that the assessment, in any event, would have been deemed to be made at the time of pick-up on the basis that delivery by courier constituted mailing as he was reluctant to make a finding on whether "mail" included courier delivery.