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Gilbert c. Canada (Revenu National), 2014 CF 890 (St-Louis)–You can’t use CRA Taxpayer Relief & Federal Court judicial review to challenge an assessment

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The taxpayer challenged three different CRA assessments, with some success, in the Tax Court of Canada and the Federal Court of Appeal. (There were at least four hearings overall; the SCC refused leave to appeal the FCA decision on the appeal of the s. 160 non-arm’s length transfer assessment.)  

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:

“[34]  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. 

“[37]  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) Inc2013 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) 

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