I have written several posts about the difficulties posed for taxpayers and the CRA by subsection 231.2(2) of the Income Tax Act. Earlier this year, the Federal Court released another decision—All Saints Greek Orthodox Church v. M.N.R., 2006 FC 374—relating to the subsection. The decision illustrates well the difficulties created for the CRA by the subsection and by the decision of the Federal Court in Redeemer Foundation v. M.N.R., 2005 FC 1361, which I discussed in an article here.
