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The Federal Court dismissed two judicial review applications challenging the Minister’s partial denial of taxpayer relief for interest and penalties under s. 281.1 of the Excise Tax Act.
The Federal Court dismissed a judicial review of a taxpayer relief decision, finding the Minister’s delegate reasonably refused additional interest and penalty relief.
Judicial review allowed where the Federal Court found the CRA’s taxpayer-relief decision under s. 220(3.1) of the Income Tax Act was unreasonable.
The Federal Court set aside a taxpayer relief refusal, finding the delegate unreasonably focused on the date of a lawsuit and failed to engage with its substance.
The Federal Court found the CRA’s decision unreasonable for failing to address Rawlings’ actual request to amend his 2004 tax return and ordered expedited redetermination.
Federal Court dismissed an application for judicial review of CRA taxpayer-relief denials for 2021 and 2022, finding the decision reasonable and procedurally fair.
The Tax Court dismissed Mr. Tolley’s application to extend time to object to reassessments, holding objections to the 2011 and 2012 reassessments were barred by the Act.
Application for judicial review dismissed. The Court held that the Minister reasonably refused taxpayer-relief under s. 220(3.1) of the Income Tax Act.
The appeal is allowed because the CRA's reasons were inadequate: the decision letter failed to explain the basis for distinguishing Bonnybrook or for concluding s.220(3) could not be relied on to extend s.164(1), and the CRA did not record or solicit submissions on that theory; the proper remedy is to set aside the Federal Court judgment and remit the matter to the CRA to permit submissions and to redetermine with adequate reasons; the court will not itself grant the discretionary tax relief.
Source excerpt
The Federal Court dismissed a judicial review of the Minister’s refusal to grant taxpayer relief for penalties and interest under the Income Tax Act.
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