Making an application for fairness—or “taxpayer relief” as it is now called—is often a frustrating process for a tax professional. One wonders, sometimes, whether the CRA agent responsible even reads the application.
The CRA has issued Information Circular IC07-1 about how it handles relief requests, in a perfect world. Dobson v. Canada (Attorney General), 2007 FC 565, is an example of how the process goes off the rails.