Dupont Roofing & Sheet Metal Inc. v. Canada (National Revenue), 2011 DTC 5031 [at at 5614], 2011 FC 160 -- summary under Subsection 223(3)

In finding that the taxpayer's tax debt had been properly certified, Mosley J. found that the Minister had mailed the notice of assessment but went on to note, in the alternative, that a notice of assessment was not actually required. While there was a line of cases imposing such a mailing requirement, those cases pertained to personal income taxes, not to payroll source deductions.