Parent v. The Queen, 2003 DTC 1002, 2003 TCC 509 -- summary under Subsection 169(1)

By services, 28 November, 2015

After the Minister issued a Notice of Confirmation of a previous reassessment of the taxpayer that reflected additional income alleged to arise from a particular transaction, the Minister issued a further reassessment which also included tax arising from alleged shareholder benefits conferred on the taxpayer. Mogan T.C.J. found that as this further reassessment fixed the tax liability of the taxpayer for the year rather than merely an amount of tax in addition to that which had already been assessed, the previous reassessment was rendered a nullity. The taxpayer was given until a specified date to file an amended notice of appeal challenging the subsequent reassessment, failing which the previously commenced appeal would be quashed.

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