He then sought interest relief on the basis that the assessments were invalid and made in bad faith. CRA initially refused relief; so he applied for a second administrative review and CRA allowed some relief for a period of delay during the second level review, but no other relief. The taxpayer then sought judicial review of the CRA decision, in the Federal Court. The Court refused:
" It seems clear that the applicant seeks to do indirectly what he cannot do directly, that is to contest anew the validity of the notices of assessment sent to his attention.
" In other words, these notices of assessment are, for purposes of the application of the law, valid. Neither the [CRA] officer, nor the Court can proceed with a new examination of these notices or to judge their validity. That task belongs to the TCC (Canada (Minister of National Revenue) v JP Morgan Asset Management (Canada) Inc, 2013 FCA 250 (CanLII), 2013 FCA 250)."
The FC ordered the taxpayer to pay $10,000 for the Crown's costs, a "sum that approaches that which would be due on the highest scale of Tariff B of the Rules of the Federal Court", due, in part to the inflammatory statements of the taxpayer.
[Decision in French. My translation.]
See Gilbert c. Canada (Revenu National), 2014 CF 890 (St-Louis)