Action for damages against CRA regarding tax debt collection and lien dismissed on summary judgment.
The CRA moved for summary judgment to dismiss an action brought by self-represented taxpayers for damages relating to the collection of an income tax debt and a property lien.
The Federal Court found there was no genuine issue for trial, noting the action was filed outside the applicable two-year limitation period, was essentially an impermissible collateral attack on a tax assessment outside the Court's jurisdiction, and failed to establish any duty of care owed by the CRA or a breach of constitutional rights.
