The taxpayer agreed to a reassessment of its taxes that disallowed a deduction of $170,000 but offset the resulting income inclusion through the carry back of losses sustained in subsequent taxation years. The taxpayer's application for waiver of a portion of the interest and penalties relating to the reassessment, based on it not having been told that there would be $24,087 in interest payable and on it experiencing cash flow problems, was dismissed. The agreement signed by the taxpayer indicated that the income tax payable resulting from the proposed change would be subject to interest at the prescribed rate, there was no incorrect advice given by an auditor that the reassessment would not result in income tax being owing, the Minister did not act in bad faith, and there was no breach of the principles of fundamental justice or consideration of extraneous or irrelevant factors.
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