Tax assessments produced under cover of the Commissioner's certificates are conclusive evidence of amounts due in recovery proceedings, and the taxpayer cannot challenge the correctness of assessments in such proceedings. A stay of tax recovery proceedings or execution pending review will not be granted merely because an appeal or review is pending or because there is an arguable case; the legislative policy strongly favours the Revenue. A stay may be warranted only in cases of abuse of position by the Commissioner or extreme personal hardship. Where assessments are conclusive, there is no overlap of factual issues between the recovery proceeding and concurrent criminal proceedings, so no real injustice arises from refusing a stay on that ground.
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