- Parties: The applicants were Latigo Trucking Ltd. and Maverick Oilfield Services Ltd. The respondent was the Attorney General of Canada. 

- Subject Matter: Under s. 220(3.1) of the Income Tax Act, 1985, the applicants filed applications for taxpayer relief from interest and penalties accrued during their 2014–20 taxation years, primarily due to a former chief executive officer’s mismanagement of the corporations, which caused them to fail to comply with their payroll remittance obligations under s. 153 of the Act. In response to these applications, the Minister of National Revenue made three review decisions on behalf of the Canada Revenue Agency. The applicants filed consolidated judicial review applications. 

- Ruling: The court ruled in the applicants’ favour; granted the consolidated judicial review applications; quashed the three review decisions of the Minister of National Revenue dated Nov. 2, 2021; and remitted the applicants’ requests for relief to a different decision-maker. While s. 220(3.1) of the Act gave the Minister broad discretion to grant taxpayer relief and the Minister did not fetter this discretion, the court found the decisions unreasonable for failing to meaningfully consider circumstances potentially beyond the applicants’ control, namely the former CEO’s mismanagement of the corporations. 

- Date: The hearing was set on Nov. 15, 2023. The court released its decision on Dec. 20, 2023. 

- Venue: This was a federal case before the Federal Court. 

- Amount: The court awarded the applicants costs of $5,176.50 for fees and GST, plus their disbursements.