Cole v. Canada (Attorney General), 2005 DTC 5667, 2005 FC 1445 -- summary under Subsection 169(1)

The availability of an appeal right to the taxpayer under s. 169(1) did not lessen the obligation of the Minister to assess with "all due dispatch". A refusal of the Minister to waive interest that accrued against the taxpayer was referred back to the Minister for reconsideration partly on the basis that the Minister had delayed considering the taxpayer's objection for the taxation years in question on the basis that there was litigation respecting an earlier taxation year of the taxpayer.