Wharton v. The Queen, 92 DTC 6582, [1993] 1 CTC 10 (FCTD) -- summary under Agency

The taxpayer's accountant, whose name and address appeared on the back of its tax returns, received a refund cheque, fraudulently endorsed it and deposited it to his account. Given that there was no indication that the accountant was clothed with the authority of discharging the debt of the Crown to the taxpayer, such cheque did not constitute payment of amounts owing by the Crown to the taxpayer. [C.R: "Payment and Receipt"]