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Judicial review of decision denying taxpayer relief from arrears interest dismissed as reasonable.
The applicant sought judicial review of a Canada Revenue Agency decision denying his request for taxpayer relief from arrears interest under section 220(3.1) of the Income Tax Act.
The arrears stemmed from a 1998 charitable donation deduction involving a hedge fund that was subsequently reassessed.
The applicant argued the denial was unreasonable given a previous settlement to reconsider the matter.
The Federal Court found the decision maker's reasoning justified and intelligible, concluding that the CRA's decision to deny relief, based on the applicant's failure to address the balance and lack of CRA delay, was reasonable.
The application for judicial review was dismissed.
