The applicant, a temporary employment agency, sought judicial review of a decision by the Minister of National Revenue denying its request for relief from debts, interest, and penalties under subsections 153(1.1) and 220(3.1) of the Income Tax Act.
The applicant argued that the CRA had misconstrued the Excise Tax Act regarding GST/HST payments, forcing the applicant to prioritize those payments over payroll remittances and causing undue financial hardship.
The Federal Court held the decision was reasonable, finding that the Minister appropriately concluded the CRA had not misinterpreted the legislation and that the applicant's circumstances did not warrant relief.
