All Saints Greek Orthodox Church v. Canada (Minister of National Revenue), 2006 DTC 6264, 2006 FC 374 -- summary under Subsection 231.2(3)

A charity auditor had acted improperly when he handed over a list of donors, who had contributed comic books to the appellant, to the tax avoidance section. On his ex parte application to subsequently obtain the list of the donors pursuant to an s. 231.2 application, the Minister failed to disclose that the CRA tax avoidance section was already using the list obtained during the charity audit. In these circumstances, the appropriate remedy was to penalize the CRA by way of costs on a solicitor-client basis and to insist that the CRA reassess taxpayers on the basis of the list that was ordered to be produced by the Court rather than on the basis of the list previously provided.