Question juridique clé
Whether definitive legal opening could be granted in a debt collection for payment without a final tax assessment
Solution extraite
No. In a payment debt collection, a final tax assessment is required; a merely enforceable security decision is insufficient.
Motifs extraits
The court followed the federal court's guidance and held that, although a security decision is immediately enforceable and may function as a legal-opening title in some settings, a payment enforcement requires a final and enforceable tax assessment. None existed yet.