Cassidy – Federal Court reverses CRA’s declining to provide significant interest relief due to its failing to engage with the taxpayer’s financial hardship request

The taxpayer requested interest relief under s. 220(3.1) primarily based on his inability to pay due to his divorce, the 2008 economic downturn, and the COVID-19 pandemic. The decision of the CRA reviewing officer to provide only very limited relief was found by Fothergill J to be unreasonable because the officer failed to engage with those submissions, so that the application for judicial review was allowed.

Neal Armstrong. Summary of Cassidy v. Canada (Attorney General), 2024 FC 174 under s. 220(3.1).