http://decisions.fca-caf.gc.ca/fca-caf/decisions/en/item/71989/index.do 
Klundert v. Canada (June 16, 2014 – 2014 FCA 156) is another chapter in the long history of Mr. Klundert before the courts:
[3] The facts providing context for the issues in dispute here are not themselves disputed. The Appellant, an optometrist practising in Windsor, Ontario, either filed tax returns showing nil income or failed to file tax returns between 1993 and 1997 taxation years and was investigated by audit at first and then subject to a criminal investigation pursuant to which a warrant for search and seizure was executed pursuant to section 487 of the Criminal Code, R.S.C. 1985, c. C-46, as amended. The Appellant had three trials before the Ontario Superior Court of Justice on tax evasion, two appeals before the Ontario Court of Appeal, and leave to appeal to the Supreme Court of Canada was denied. The third and last trial before the Ontario Superior Court of Justice, by jury, was decided on May 20, 2010, in which the Appellant was convicted of tax evasion under section 239 of the
Income Tax Act (the “Act”); which conviction was appealed to the Ontario Court of Appeal which dismissed his appeal on September 12, 2011, and for which leave to appeal to the Supreme Court of Canada was denied on April 5, 2012. Based on the findings of this third trial, in which the Appellant was found to have failed to report respective amounts of $241,625, $270,403, $434,931, $254,520 and $272,910 for the years from 1993 to 1997, the Canada Revenue Agency (“CRA”) reassessed his income taxes on exactly the same basis.
http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/31220/index.do
This decision arose out of a seizure of funds under a jeopardy order. Mr. Klundert applied to the Federal Court for an order that the seized funds be applied to the payment of the fines payable by him as a result of his criminal conviction (presumably to avoid imprisonment for failure to pay the fines). The Federal Court dismissed his application and he appealed to the Federal Court of Appeal.
The court rejected his challenge based on the Jarvis decision of the Supreme Court of Canada:
[11] The concern that animated the Court in Jarvis was that when the predominant purpose of an inquiry is the determination of penal liability, the full panoply of Charter rights are engaged for the taxpayer’s protection.
[12] The appellant does not challenge the validity of any search warrant used to collect evidence for the criminal investigation. It follows that there is no basis to conclude that any of the appellant’s Charter rights were violated and no reason to conclude that properly obtained evidence could not also be used in support of the motion for a jeopardy order.
Similarly the court rejected his argument that the Crown was using criminal powers to enforce a civil debt:
[13] Second, I disagree that the Canada Revenue Agency used its criminal powers to enforce a civil debt. The Judge found as a fact that, based on the appellant’s conduct (such as his position that “collecting income tax by the government is against the Constitution of Canada”), the authorities had every reason to believe the appellant would not voluntarily pay his taxes.
The court held that these proceeding amounted to a collateral attack of prior proceedings attacking the jeopardy order:
[18] In the present case, the jeopardy order was reviewed under subsection 225.2(8). On the first review the appellant sought an order quashing the search warrants and an order excluding evidence obtained as a result of the search warrants pursuant to subsection 24(2) of the Charter of Rights and Freedoms. The jeopardy order was upheld. The appellant then sought a second review challenging the collection of 100% of his income. He again alleges abuse of the Canada Revenue Agency’s audit/administrative and investigative powers and again asserts that 100% of his income ought not to be subject to execution. To the extent these matters were dealt with on the review of the jeopardy order, this motion constitutes a collateral attack on the jeopardy order proceedings.
Finally the court addressed his argument based on section 7 of the Charter:
[19] That leaves for consideration the appellant’s argument that non-payment of the criminal fines exposes him to risk of incarceration so as to engage section 7 of the Charter.
[20] Assuming, without deciding that such a threat engages section 7, the appellant has failed to demonstrate that the process followed to date, or to be followed, was or is not in accordance with the principles of fundamental justice.
As a result the appeal was dismissed with costs.