Précis: The taxpayer was reassessed on July 9, 2009 for its 2004 and 2005 taxation years. It duly filed notices of objection in a timely manner. After some back and forth the appeals officer wrote to the taxpayer on August 26, 2011 proposing to vacate the 2004 reassessment as part of a settlement offer. After more discussion reassessments were issued on December 19, 2011 for both the 2004 and 2005 taxation years. The taxpayer argued that the December 19, 2011 reassessment of its 2005 taxation year was out of time because of the August 26, 2011 letter had vacated the 2004 reassessment, not reassessed, which meant that the later reassessment of 2005 was not a “consequential” assessment.
Ford Credit Canada v. R. - TCC: Letter from appeals officer did not vacate assessmentREAD MORE »