In a previous hearing, the Federal Court ordered a redetermination of taxpayer's application for s. 220(3.1) relief. Martineau J. affirmed the Minister's decision to again deny such relief, and noted (at paras. 13-15) a number of factors that demonstrated that the review process had been fair, including that the redetermination was carried out by a different CRA office than the first, by personnel who had no prior exposure to his case, and that the taxpayer had been given a chance to comment in person on the Technical Advisor's draft report and present arguments.
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