Costabile v. CCRA, 2008 DTC 6574, 2008 FC 943 -- summary under Subsection 152(4.2)

Before going on to find that the Minister's decision not to accept amended returns was not unreasonable, Russell, J. noted (at para. 24) that "the Supreme Court of Canada in Dunsmuir v. New Brunswick, 2008 SCC 9, recently collapsed the patent unreasonableness and reasonableness simpliciter standards into one standard of reasonableness, leaving now only two standards of review: reasonableness and correctness". Russell, J. also noted that the Minister's powers to reassess after the normal reassessment period under s. 152(4.2) did not extend to corporations.