JP Morgan - Federal Court of Appeal provides a primer on administrative law remedies (which are a "last resort")

"Armed with sophisticated wordsmithing tools and cunnng minds, skilful pleaders can make Tax Court matters sound like administrative law matters..." (para. 49).

Stratas JA wasn't fooled.  The taxpayer was unsuccessful, in its application for judicial review, to have some Part XIII tax assessments set aside on the basis that they were contrary to the Minister's policy to not go back more than two years on audit.

He thoroughly reviewed administrative law in an income tax context (perhaps to discourage taxpayers from bringing further clear-loser applications).

Neal Armstrong.  Summary of MNR v. JP Morgan Asset Management (Canada) Inc., 2013 FCA 250 under Federal Court Act, s. 18.5.