The taxpayer was convicted for failing to comply with the Minister's demand for information under the Income Tax Act.
The Minister subsequently made a second demand for the same information, and the taxpayer was convicted again.
The Court of Appeal set aside the second conviction, holding that only one demand could be made.
The Supreme Court of Canada allowed the Crown's appeal, holding that further demands by the Minister create fresh time periods for compliance and fresh offences for non-compliance, as the purpose of the provisions is to enforce compliance with the self-assessment system of taxation.
