The taxpayer failed to pay federal and provincial taxes for the 1980 to 1985 taxation years.
Revenue Canada assessed the taxpayer in 1986 but took no collection action until 1998.
The Crown appealed a decision holding that it was statute-barred from collecting the tax debts.
The Supreme Court of Canada dismissed the appeal, finding that the six-year limitation period prescribed by section 32 of the Crown Liability and Proceedings Act applies to the statutory collection procedures under the Income Tax Act.
The Court also held that the provincial tax debt was barred by the six-year limitation period under the British Columbia Limitation Act.
