SAMUEL COZAK c. PGC
Samuel Cozak
Law Firm / Organization
Unrepresented
Attorney General of Canada
Law Firm / Organization
Department of Justice Canada
Lawyer(s)

Alice Zhao Jiang

Background:

  • Cozak sought judicial review of Canada Revenue Agency (CRA) decisions denying him benefits under CERB, CRB, CRSB, and CWLB.
  • The CRA officer found Cozak ineligible due to failure to meet eligibility requirements, including the income criterion and the relationship of his work reduction to COVID-19.
  • Cozak, a law school graduate who did legal work for lawyers, argued procedural unfairness and inadequate reasoning by the CRA officer.

Legal Issues:

  1. Eligibility for Benefits: Examining the reasonableness of the CRA's denial of emergency benefits to Cozak.
  2. Procedural Fairness: Assessing whether Cozak was provided adequate opportunity to present his case and if the CRA’s decision-making process was fair.
  3. Sufficiency of CRA's Reasons: Determining if the CRA officer provided adequate reasons for the decision.

Judgment:

  • Judge: Vanessa Rochester
  • Decision: Judicial review applications dismissed.
  • Reasoning:
    • The Court found no breach of procedural fairness. Cozak was given multiple opportunities to provide additional information, which he did not utilize.
    • The decisions were reasonable, based on the evidence and Cozak's failure to adequately demonstrate eligibility.
    • The CRA officer’s reasons, including notepad entries and review reports, were considered sufficient.
  • Costs: Cozak ordered to pay $750.00 in costs to the Respondent.

Conclusion:

  • The Federal Court upheld the CRA's decisions, emphasizing the importance of engaging with the review process and the sufficiency of the provided reasons in administrative decision-making.
Federal Court
T-1601-22
Taxation
$ 750
Respondent
11 July 2022