The applicant sought judicial review of a decision by the Minister of National Revenue refusing a request for taxpayer relief to waive interest and penalties on outstanding tax liabilities from 1989 and 1991.
The applicant argued the Minister failed to adequately consider the delay, the lack of enforcement steps by the CRA since 1996, and the relief granted to the applicant's company.
The Federal Court held the decision was reasonable and fair, noting the applicant was repeatedly advised of the debt, the Minister had no duty to take enforcement steps to reduce interest, and the Minister was not required to review the records of a related taxpayer.
The application was dismissed.