Besner v. The Queen, 2008 DTC 4299, 2008 TCC 404 -- summary under Subsection 239(3)

A CRA auditor referred the taxpayer's file to the Investigative Division of the CRA, then the Minister assessed the taxpayer for a gross negligence penalty, and a month later an Information was laid which charged the taxpayer with evading income tax. The taxpayer unsuccessfully argued that the referral of the file to Investigations was a "complaint" within the ordinary meaning of that term. V.A. Miller J. found (at para. 19) that :the term 'complaint' does not have its ordinary, everyday meaning ... [and] it has a legal meaning that refers to a process which initiates a judicial proceeding".