"The Minister is not required to prove misrepresentation before he sends out a notice of reassessment which is dated beyond the 4 year [now 3 year] time period provided for in the statute. Misrepresentation must be proved only if the matter goes to trial." After minutes of settlement were entered into by the taxpayer and the Minister with respect to share transactions which had taken place outside the normal limitation period, the taxpayer unsuccessfully argued that the Minister was required to prove misrepresentation before a settlement judgment could be entered.
Topics and taglines
Tagline
proof of misrepresentation not required before settlement agreement
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
334497
Extra import data
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"field_legacy_header": "<strong><em>Davis v. The Queen</em></strong>, 84 DTC 6518, [1984] CTC 564 (FCTD) <strong>[proof of misrepresentation not required before settlement agreement]</strong>",
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