http://decisions.fct-cf.gc.ca/fc-cf/decisions/en/item/71473/index.do 
Hunter v. Canada Revenue Agency (October 19, 2012 – 2012 FC 1223) was an application for a judicial review of an unsuccessful taxpayer relief application to the Minister. In substance the court denied the application on the basis that the taxpayer was attempting to dispute the underlying tax liability:
[3] The application submitted by the Applicant stated that relief was sought on all three of the above grounds. However, the argument in the accompanying narrative, while citing delays of the CRA, is essentially based on the Applicant’s view that her tax liability was not warranted. The narrative outlines the circumstances that led to the Applicant’s tax liability and expresses the Applicant’s view that the CRA mishandled her audit. It also cites the length of time it took for the CRA to complete the audit and the subsequent appeals. The “extraordinary circumstances” cited by the Applicant on Form RC4288 of the application relate to the CRA’s conduct during the audit and expresses the view that legitimate expenses were denied in the course of the taxpayer’s audit. Thus, I find that the Applicant supported her application with grounds well outside the scope of the Guidelines.
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[8] During the course of the present hearing, the Applicant argued that she was entitled to another opportunity to make her case before the CRA. When pressed to identify the unfairness of not receiving another chance, the Applicant articulated that a second-level assessment would provide another opportunity to demonstrate to the CRA that mistakes were made in the course of her tax audit. I find that this argument was made on a continuing mistaken impression that the interest and penalty relief regime is a means to remedying the perceived errors of the CRA in assessing her tax liability. As a result, I give the argument no weight.
[9] However, during the course of the hearing the Applicant did point to CRA documents, disclosed in the course of this judicial review, which she argued do indicate that the CRA had incorrect information with respect to the Applicant’s compliance with her tax obligations. This is a factor cited in the Guidelines as a relevant consideration when considering whether her relief is warranted. The Applicant argued that a second-level assessment would provide the opportunity to correct this information. However, I find that because the Minister’s Decision does not rely on the identified information, its existence is not a relevant consideration on the present Application.
[10] In conclusion, given the above analysis, I find that there is no basis upon which to find that the Minister’s decision is unreasonable.
The court made no order as to costs.