The taxpayer's application for relief based on his being "de facto bankrupt" was rejected by a CCRA officer who did not have appropriate delegated authority. The taxpayer's application for judicial review was dismissed because "if the decision under review were set aside and referred back, the same decision would necessarily follow by reason of the reality that the concept of de facto bankruptcy is simply not recognized within the scope of the Income Tax Act in a way that would permit any relief of the nature sought by the Applicant". (p. 5327)
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