http://decisions.fca-caf.gc.ca/en/2013/2013fca173/2013fca173.html 
A&E Precision Fabricating and Machine Shop Inc. v. The Queen[1] (June 26, 2013) is a decision of the Federal Court of Appeal where the taxpayer appealed to increase a cost award against CRA. The main point of the appeal concerned the quantum of witness fees and is of little interest. A subsidiary question was whether CRA was entitled to set off the costs payable to the taxpayer against the taxpayer’s tax debt owing. The Federal Court of Appeal once again confirmed that the Tax Court had no jurisdiction over the collection procedures followed by CRA:[2]
[8] Next, the Judge found that the respondent had set off its obligation to pay the taxed costs against the appellants’ tax debts, and that the Tax Court had no jurisdiction to review such set off.
[9] We agree that the Tax Court had no jurisdiction to review the respondent’s set off. In the present cases, the jurisdiction of the Tax Court was limited to hearing and determining the appeals brought under the Act (subsection 12(1) of the
Tax Court of Canada Act, R.S.C. 1985, c. T-2). This does not include the power to review collection procedures employed by the respondent. Jurisdiction with respect to collection procedures lies with the Federal Court.
[1] 2013 FCA 173.
[2] Id per Dawson JA.