The taxpayer had accumulated interest from a tax debt in a prior taxation year. He applied for relief from the interest on the basis that the Minister had misled him into thinking that there was no outstanding debt in the intervening years.
Barnes J. affirmed the Minister's decision to deny relief. The taxpayer's assertions about being misled lacked an air of reality, given that he had filed documents with CRA which clearly indicated that he was aware of his tax debts. Even if the taxpayer were unaware of his debts, it was not clear that there had been any detrimental reliance, i.e. that the taxpayer would have paid down his debt at all.