In response to the disallowance by the trustee in bankruptcy of an assessment, Zuber J.A. stated:
"When the trustee in bankruptcy wishes to question the validity of an assessment against a bankrupt he, like anyone else, must seek his remedy within the Income Tax Act. ... To hold that the trustee in bankruptcy can disallow an assessment made pursuant to the Income Tax Act would be tantamount to clothing the trustee with the powers of the Tax Court. No interpretation of the Bankruptcy Act, R.S.C. 1985, c. B-3, can support such a conclusion."