Applicant
Respondent
Applicant's Request: Iain Paterson, the applicant, sought judicial review of a decision by an employee of the Canada Revenue Agency (CRA) made on January 10, 2023. This decision denied his application for benefits under the Canada Recovery Benefits Act.
Basis of the Application: Paterson claimed that he met the income requirements for the benefits, citing his total income in 2019 and the fact that his tax return was filed and assessed before the pandemic shutdowns and the policy introduction in 2020.
CRA's Decision and Subsequent Review: The CRA initially found Paterson ineligible for benefits due to not meeting the $5,000 income requirement. Upon his request, a second review was conducted, which upheld the initial decision. Paterson then filed for a judicial review of the July 2022 decision, which was set aside and his file referred for redetermination. However, the third review by Ms. Holly Horvath, another CRA officer, again concluded his ineligibility.
Applicant's Argument: Paterson argued that his income as assessed for tax purposes should qualify him for the benefits. He expressed dissatisfaction with the CRA's decision and lack of explanation for why his declared and taxed income for 2019 did not meet the eligibility criteria.
Court's Analysis and Decision: The court reviewed the case, focusing on the procedural fairness and reasonableness of the CRA's decision. It was found that Paterson was given the opportunity to present his case and that the CRA's decision was justified, transparent, and intelligible based on the available evidence.
Final Judgment: The application for judicial review was dismissed, with the court finding no breach of procedural fairness and that the CRA's decision was reasonable based on the evidence presented. No order was made regarding costs.
Court
Federal CourtCase Number
T-165-23Practice Area
TaxationAmount
Winner
RespondentTrial Start Date
19 January 2023Download documents