Tolhoek v. The Queen, 2007 DTC 247, 2006 TCC 681 (Informal Procedure), aff'd 2008 FCA 128 -- summary under Subsection 143.2(15)

The taxpayer unsuccessfully submitted that it was not "necessary" for the Minister to have reassessed beyond the normal limitation period on the basis that the necessary facts underlying the assessment were known to the Minister prior to the expiration of the normal reassessment period. This submitted interpretation of "necessary" was not consistent with a unified textual, contextual and purposive interpretation.