Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260 -- summary under Interpretation Bulletins, etc.

Sexton J.A. noted (at p. 7120) with approval the indication in Canadian Occidental (U.S.) Petroleum Ltd. v. The Queen, 2001 DTC 295 (TCC) that "while the administrative position of Revenue Canada is not declarative of the law, it is nonetheless of assistance in circumstances where the Minster seeks to reassess the taxpayer in a manner inconsistent with its own administrative position."