Is there any case law where mere suspicion that collection may be delayed is insufficient?

Alberta, Canada


The following excerpt is from Canada (Minister of National Revenue) v. Goldland Jewelers Ltd., 2006 ABQB 108 (CanLII):

The Applicant has brought to my attention cases which set out that mere suspicion that collection may be delayed is insufficient. I agree. See Danielson v. Canada (1986), 86 D.T.C. 6518 (F.C.T.D.) at 6519

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