Sherry v. Canada (National Revenue), 2011 DTC 5168 [at at 6247], 2011 FC 1208 -- summary under Subsection 220(3.1)

Simpson J. found that the Minister's decision to deny relief was not given with adequate reasons, but the taxpayer could not establish that it was unreasonable. In the course of so finding, she found that the rules of procedural fairness did not entitle the taxpayer to comment on CRA's preliminary conclusions before the final decision was made (paras. 16-18).