Chudina v. Deputy Attorney General of Canada, 88 DTC 6043, [1988] 1 CTC 303 (BCSC) -- summary under Subsection 225.2(2)

On December 17, 1986, the Minister assessed the taxpayer, mailed the assessment and a demand for payment, obtained a judgment under s. 223(2) and obtained process of execution, and on the next day executed that process. The Minister had no such right to take such jeopardy proceedings because a condition precedent to the taking of such proceedings was that the taxpayer have been given an opportunity to pay.