Stremler v. The Queen, 2000 DTC 1757 (TCC) -- summary under Estoppel

By services, 28 November, 2015

The Crown was unsuccessful in a submission that the taxpayers were estopped from alleging that properties held by them were inventory rather than being held on capital account as originally characterized in their income tax returns. McArthur TCJ. stated (at p 1760):

"... Appellants' description of the properties as capital is a statement of law and not fact. A representation of law is not grounds for estoppel."

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