Does stoppel have to lie to override a statutory provision in the Income Tax Act?

Canada (Federal), Canada

The following excerpt is from Beauchamp v. The Queen, 2004 TCC 371 (CanLII):

In Holitzki v. Canada, [1998] T.C.J. No. 1146, at paragraph 7 (Q.L.), Rowe J. explained that "[t]he law is clear that stoppel will not lie to override a statutory provision; in this case the Income Tax Act."

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