http://decisions.fct-cf.gc.ca/fc-cf/decisions/en/item/72194/index.do 
Matsui v. Canada (June 10, 2014 – 2014 FC 553) was an application to extend the time to judicially review the Minister’s refusal to accept certain losses claimed by the taxpayer and for an injunction staying collection action:
[4] In this regard, Mr. Matsui has an outstanding debt for unpaid taxes in the approximate amount of $28,000.00. In April 2009, Mr. Matsui claimed business losses for the 2005 taxation year. CRA requested documents to substantiate this claim, but Mr. Matsui did not provide them. In 2007 and 2008 he sent CRA documents that he claims unilaterally extinguished his tax debt, which, of course, they did not. In 2009, he retained Demara Consulting Inc. [Demara] as his representative to the CRA; Demara’s principals were subsequently charged with tax fraud associated with claiming fraudulent expenses.
[5] In May 2012, Demara filed amended tax returns on Mr. Matsui’s behalf for the 2001 and 2005 taxation years. In them, Demara claimed additional business losses. Once again CRA wrote to Mr. Matsui and his representatives, requesting documentation to support the claimed expenses. Once again, Mr. Matsui provided nothing in reply.
[6] On January 14 [sic], 2014, the CRA wrote to Mr. Matsui and told him that as he had not produced the requested information it had assessed his claims based on the information available to it, and in light of this information, had disallowed the losses claimed. On March 20, 2014, CRA issued the Requirement to Pay to ARC, a company Mr. Matsui indicates he works for as a contractor.
[7] Mr. Matsui did not file this motion until April 8, 2014, and the evidence before me indicates that he took no steps to seek to review the CRA’s January 24, 2014 decision until after the Requirement to Pay was served on ARC.
The court refused the extension application because (a) there was no evidence of his continuing intent to appeal the January 24, 2014 decision until the Requirement to Pay was served, (b) the application lacked merit, and (c) there was no explanation for his delay.
The injunction to restrain the collection action was denied as there was no proceeding before the court and he had not raised a serious issue:
[15] This determination must necessarily result in the dismissal of Mr. Matsui’s request for relief in the nature of an injunction, suspending the effect of the Requirement to Pay served on ARC. This Court possesses jurisdiction to issue such relief under s. 50 of the FCA only ancillary to proceedings that are pending before the Court. As I have denied Mr. Matsui permission to commence such a proceeding, there is no basis for the award of the injunctive-type relief he seeks.
[16] Moreover, he has in any event failed to meet one of the necessary prerequisites for such relief, namely, that his application raise a serious issue. For the reasons set out above, Mr. Matsui’s judicial review application fails to raise any such issue.
The application was dismissed without costs as the Crown had not sought costs.