Delle Donne v. The Queen, 2015 TCC 150 -- summary under Subsection 171(1)

Respecting an argument that the taxpayer was required by s. 20(1)(l) or (p) to have "included" the interest in income before being entitled to the reserve – whereas, in fact, neither income nor deduction appeared in the return (although an explanatory letter was attached) - Owen J stated "in any event…it is well established that it is open to a taxpayer to amend his return through the appeal process [citing Imperial Oil, 2003 FCA 289, at para. 10]" (para. 91). See summary under s. 20(1)(p)(i).