Taylor v. The Queen, 2010 DTC 1189 [at at 3449], 2010 TCC 246 -- summary under Subsection 169(2.2)

In finding that a waiver signed by the taxpayer of his rights to appeal, which he had agreed to in a meeting with CRA where it agreed to waive gross negligence penalties, was binding on the taxpayers, Woods, J. noted (at para. 68) that the evidence did not establish that there was "an inequity of bargaining power due to ignorance, need or distress" and that there was not a sufficient evidentiary foundation for her to conclude that the settlement was more favourable to the government than to the taxpayer.