First, we don't look at every appeal that comes through. The Income Tax Act does have a series of provisions that govern when taxpayers can appeal their tax assessments and when no appeal is allowed.
In general, no appeal is allowed in circumstances where there's no tax in dispute, and I don't think it takes a lot of imagination to figure out why, as a general rule, that would be the case, the workload being as it is both for the courts and for the CRA.
However, there are some circumstances where--