Maarsman v. Canada (Customs and Revenue Agency), 2003 DTC 5677, 2003 FC 1234 -- summary under Subsection 220(3.1)

The decision of the Minister not to cancel interest and penalties was referred back to CCRA for reconsideration based on there having been a failure to apply ss.161(1) and (7) fairly, there having been an incorrect belief that the taxpayer was not aware of her obligation to file a 1987 return, and in light of the considerable delays of the CCRA in dealing with the taxpayer's second fairness request thereby resulting in further accruals of interest.