...First, an appeal must be directed against an assessment and an assessment which assesses no tax is not an assessment (see Okalta Oils Limited v. MNR, 1955 CanLII 70 (SCC), 55 D.T.C. 1176 (SCC) at p. 1178: “Under these provisions, there is no assessment if there was not tax claimed”). Second, there is no right of appeal from a nil assessment since: “Any other objection but one related to an amount claimed [as taxes] was lacking the object giving rise to the right of appeal ...” (Okalta Oils, supra, at p. 1178).
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