http://decisions.fct-cf.gc.ca/site/fc-cf/decisions/en/item/63485/index.do 
Johnson v. The Queen (The Minister of National Revenue)[1] (October 11, 2013) involved assessments and collection activity arising out of alleged criminal activity:
[4] On April 17, 2012, Sergeant Jay Bentham of the Royal Canadian Mounted Police [RCMP] telephoned Terence Finlay, a CRA auditor in the Special Enforcement Program [SEP]. The SEP is a section within the Enforcement Division of the CRA. Its mandate is to conduct audits and undertake other civil enforcement actions of persons known or suspected of deriving income from illegal activities. Subsequent to this call, Sergeant Bentham emailed Mr. Finlay a four-page document [the Synopsis] summarizing searches and surveillance undertaken by the RCMP in relation to the Applicant and eight other individuals. The Applicant, Danny Le and others, were alleged to be engaging in activities related to the acquisition of cocaine and the production and the distribution of “crack” cocaine and methamphetamine. It did not identify any activities undertaken by Rachel Laing, Mr. Le’s spouse.
The applicant brought what would have to be termed a very ambitious judicial review application claiming relief on a number of bases:
[2] The issues raised in the present application are as follows:
A. i) Did the Minister make an assessment of the net tax of the Partnership I or the Applicant prior to taking collection action?
ii) If the Minister made a legitimate assessment of net tax of Partnership I or the Applicant, or both, was the Requirement to Pay Reasonable Monies [RTP] authorized by the Act and, if not, what is the appropriate remedy?
B. Did the Minister issue the First Assessments for an improper purpose such that they should be quashed?
C. i) Did the Minister issue the Second Assessments for an improper purpose such that they should be quashed?
ii) Do the Second Assessments give rise to a reasonable apprehension of bias such that they should be quashed?
D. Was the Minister functus officio when he issued the Second Assessments such that those assessments are nullities?
E. If the Court declines to quash the First Assessments, should a stay be granted in respect of the CRA’s collection action pending the outcome of the appeal of the Personal NOA I in the Tax Court of Canada?
The Federal Court, in a detailed and thorough set of reasons, rejected all of the applicant’s arguments either because the validity of the assessments was within the exclusive jurisdiction of the Tax Court, the Minister’s actions were all permitted by the statute or because the applicant had failed to establish an evidentiary foundation for the extraordinary relief claimed.
[1] 2013 FC 1032.