Jaka Holdings Ltd. v. Canada Revenue Agency, 2011 DTC 5081 [at at 5831], 2011 FC 518 -- summary under Subsection 220(3.1)

Heneghan J. found that a decision from a second-level CRA review of the taxpayer's request to waive interest and penalties breached the taxpayer's procedural fairness rights, because it was substantially a copy of the first-level decision. As it was not clear what the result of an independent review would have been, the matter was referred back to be considered by a different CRA adjudicator.