Section 231.7

An application by the Minister was dismissed given that the Minister had not demonstrated that the person served with the requirement letter was the taxpayer rather than its officer in his personal capacity (as the salutation in the requirement letter was addressed "Dear Sir", and a threat of incarceration for failure to respond suggested that the letter was not directed to a corporation), and given that it had not been demonstrated that the person required to provide the requested information or documents had not done so (as there had been the production of some documents).