By David J. Rotfleisch ( September 24, 2026, 3:30 PM EDT) -- Part one of this series examined how the Federal Court of Appeal in Siam v. Canada, 2026 FCA 91 applied the Mpamugo v. The Queen, 2016 TCC 215 framework to a taxpayer’s claim that the Canada Revenue Agency (CRA) never sent his original Notice of Assessment....