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Judicial review dismissed; CRA's partial denial of taxpayer relief based on accountant error was reasonable.
The applicant sought judicial review of a decision by the Canada Revenue Agency denying full relief of penalties and interest on his tax debt.
He argued his illiteracy and his accountant's errors were exceptional circumstances justifying relief.
The Minister's Representative cancelled interest on arrears up to the point when the debt was crystalized by reassessments but upheld late filing penalties and subsequent interest.
The Federal Court found this decision reasonable, noting the applicant could have mitigated the ongoing interest by paying the crystalized assessments, and dismissed the application with costs.