Sicoli v. The Queen, 2013 DTC 1167 [at at 917], 2013 TCC 207 -- summary under Subsection 244(10)

Hershfield J found that the Minister was unable to rely on s. 244(10) in respect of 17 assessments that had purportedly all been mailed in 2009, as the circumstances around the mailing were clearly not part of CRA's usual mailing practices. Hershfield J stated that "the evidence in this case is haunted by a degree of hurried carelessness on the part of the CRA that strongly suggests the unreliability of evidence that relies on routine or ordinary practices" (para. 14).