INCOME TAX
Reassessment
Appeals from: (1) Tax Court of Canada decision quashing notices of appeal for 1991, 1993; (2) Federal Court’s (2004 FC 1353) dismissal of application for judicial review requiring Minister to make determination of loss under Income Tax Act, s. 152(1.1)—Appeals dismissed—(1) Discussion of bases upon which request for recognition of 1993 rental loss could have been considered—(2) Scope of s. 152(1.1)—Statutory conditions for remedy not met—Income Tax Act, R.S.C., 1985 (5th Supp.), c. 1, s. 152(1.1).
Armstrong v. Canada (A‑222‑04, A‑582‑04, 2006 FCA 119, Sharlow J.A., judgment dated 21/3/06, 12 pp.)
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