Kreuz v. The Queen, 2012 DTC 1201 [at at 3514], 2012 TCC 238 (Informal Procedure) -- summary under Subsection 162(2)

D'Auray J. accepted the taxpayer's argument that the Minister could not impose s. 162(2) penalties in respect of the making of a demand to file returns for the taxpayer's 2006 and 2007 taxation years because the Minister had failed to serve the required notice under s. 150(2). There was no reason to question the taxpayer's credibility, and the Minister had filed no evidence to the contrary.