http://decisions.fct-cf.gc.ca/fc-cf/decisions/en/item/108104/index.do 
MacDonald v. Canada (Attorney General) (February 13, 2015 – 2015 FC 177, Mactavish J.).
Précis: Mr. MacDonald was a farmer who had suffered years of misfortune in his businesses: a potato blight, Mad Cow disease and the softwood lumber dispute. He turned to blueberry farming but fell behind in his payroll and GST withholding and remittances. He applied for fairness relief and his application was denied. He applied to the Federal Court for judicial review. His application was denied because he had not demonstrated that CRA’s refusal was unreasonable.
Decision: The taxpayer had a long history of calamities:
[1] Earl MacDonald seeks judicial review of a decision of the Canada Revenue Agency (CRA) refusing to grant him relief from penalties and interest assessed in relation to his payroll and GST/HST accounts for a number of taxation years between 1995 and 2010.
[2] Mr. MacDonald is a 62 year old farmer living in Prince Edward Island. He based his request for fairness relief on the financial hardship that he says that he has suffered over the last several decades. Mr. MacDonald states that his economic difficulties started in the 1980s and 1990s, when poor potato prices and a virus negatively affected his potato crops. This led him to stop growing potatoes, and to go into the cattle and lumber industries. However, the emergence of “Mad Cow” disease in the 1990s caused a drop in beef prices, and the softwood lumber dispute caused the lumber market to collapse. The combined effect of these events was to leave Mr. MacDonald seriously in debt.
While the Court was sympathetic it found no basis to hold that CRA’s refusal to grant relief was unreasonable:
[14] Mr. MacDonald did not identify any error on the part of the CRA that would make its decision unreasonable. Although he raised a concern regarding the value that the CRA had ascribed to his real estate holdings, a review of the record demonstrates that this value was based on Mr. MacDonald’s own estimates as to the properties’ worth. Mr. MacDonald has not identified any irrelevant considerations that were taken into account by the CRA in concluding that he should not be afforded discretionary relief. Moreover, Mr. MacDonald’s submissions were all considered by the CRA, and he was given a clear explanation as to why his submissions were not accepted.
[15] While I am sympathetic to the financial predicament in which Mr. MacDonald finds himself, no basis has been shown for this Court’s intervention, and his application for judicial review must therefore be dismissed. In the exercise of my discretion, I have determined that each side should bear its own costs.