Montgomery v. MNR, 94 DTC 6367, [1994] 2 CTC 57 (FCTD), aff'd 95 DTC 5032 (FCA) -- text
Pinard, J.:—This is an application for judicial review of the decision of the Minister of National Revenue denying the applicants’ request pursuant to subsection 220(3.1) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, C. 63) (the "Act") for the waiver of interest. The applicants specifically request: (a) a writ of certiorari, to quash and/or set aside the Minister’s decision: and