INCOME TAX
Enforcement collection—Canada Customs and Revenue Agency (Agency) registering certificate of indebtedness in Federal Court, notices of lien against taxpayer’s real properties to recover outstanding tax debt—Taxpayer subsequently bringing appeal in Tax Court after obtaining extension of time to appeal—Income Tax Act, R.S.C., 1985 (5th Supp.), c. 1, s. 225.1 preventing Agency from taking fresh collection steps—Not expressly requiring Agency to reverse lawful collection steps in face of subsequently launched appeal, but Parliament could easily have so provided—No legal basis for requiring Agency to withdraw certificate of indebtedness or to lift liens—Application dismissed.
Alessandro v. Canada (ITA‑11539‑04, 2006 FC 895, Barnes J., order dated 19/7/06, 7 pp.)