Danada Enterprises Ltd. v. Canada (Attorney General), 2012 DTC 5083 [at at 6986], 2012 FC 403 -- summary under Section 18.5

Blanchard J. found that the taxpayer was prevented under s. 18.5 of the Federal Courts Act from challenging, before the Federal Court, the legitimacy of the Minister's notice of confirmation under s. 165(3) of the ITA. The legal efficacy of a "key document" to a taxpayer's tax liability is within the exclusive purview of the Tax Court and appeals therefrom (paras. 26-27).