http://decisions.fct-cf.gc.ca/fc-cf/decisions/en/item/72553/index.do 
Associated Mechanical Trades Incorporated v. Canada (July 23, 2014 – 2014 FC 732) was an application for mandamus to adjust the applicant’s GST and payroll accounts:
[1] This is an application for an Order of mandamus, pursuant to section 18 of the Federal Courts Act, RSC 1985, c F-7. The Applicant seeks the Order to compel the Canada Revenue Agency [the CRA] to correct alleged errors in and provide a new accounting of the Applicant’s payroll and Goods and Services Tax [GST] accounts.
I. Issues
[2] The issues in the present application are as follows:
A. Are there accounting errors in the Applicant’s GST or payroll accounts?
B. If yes, do these errors warrant the Order of mandamus sought by the Applicant?
The matter had a long history with debts dating back to 2001 and prior:
[3] The Applicant is a mechanical contracting company that was incorporated in 1996. The CRA alleges that the Applicant has payroll and GST debt outstanding [the Debts]. As of July 25, 2011, the payroll debt was $1,227,387.59 and the GST debt was $275,055.54. The calculation of these debts is the source of the dispute underlying this application.
[4] According to the Affidavit of Jon-Paul Rebellato, a Complex Case Officer with the CRA, a payroll debt was first assessed against the Applicant in 1997, and it has been carried forward since that time. This debt arises from the Applicant’s obligation to deduct applicable tax and Employment Insurance and Canada Pension Plan premiums from employee pay and remit the amounts collected to the CRA.
[5] Similarly, Mr. Rebellato states that GST debt was first assessed against the Applicant in 1997. This debt has been outstanding since 2001 and arises from the Applicant’s obligation to collect and remit GST on most of its sales.
[6] In March, 2009, Mr. Rebellato was tasked with managing the collection of the Applicant’s Debts. Mr. Rebellato alleges he spoke several times with the President of the Applicant, Edward Pupolin, but Mr. Pupolin did not agree on a repayment schedule.
The case turned on credibility as there were no significant issues of law at stake. The court preferred the evidence of the CRA witnesses:
[28] Pursuant to an Order of this Court dated April 24, 2013, the Applicant cross-examined Harish Manocha on his affidavit affirmed on November 3, 2013, for a second time. Mr. Manocha confirmed that based on his review of the Applicant’s payroll account, on or around February 23, 2010, to determine whether duplicate assessments were raised, he determined that the CRA did not raise duplicate assessments. All documents Mr. Manocha reviewed were provided to the Applicant.
[29] The Applicant’s allegations are without merit. Its claims can be reduced to the five alleged errors in the payroll accounts and the seven alleged errors in the various GST reporting periods. These are all addressed by the affidavits of Mr. Rebellato, Mr. Baker, and Mr. Manocha. Their explanations are logical and reasonable, and the Applicant has done nothing to rebut them. While the Applicant takes issue with the review of Mr. Manocha, I believe his review was reasonable, given the discrete nature of the task assigned to him. He had no need to produce notes or review the entire payroll account. The Respondent has addressed each error alleged by the Applicant in this application.
[30] Further, there is nothing in the conduct of the CRA’s representatives which would lead me to doubt the credibility of their explanations. In contrast to Ms. Masatti’s affidavit, Mr. Rebellato’s affidavit is specific with dates and the nature of the conversations he had with Mr. Middlebrook. I find it a more reliable history of the substance and nature of the interactions between the parties. It shows that the CRA’s representatives were reasonably diligent, cooperative and forthright in their interactions with the Applicant. They provided a detailed statement of the Applicant’s GST and payroll accounts, before any specific errors were alleged by the Applicant. They repeatedly sought communication with the Applicant and a means to resolve the Applicant’s debt obligations and have done so continuously up to the hearing of this application on July 18, 2014. The same cannot be said of the Applicant. The Applicant was not forthcoming with documents requested, was unavailable to Mr. Rebellato for long periods of time, and did not appear to facilitate progress on resolving the issues between the parties.
As a result the application was dismissed.