That's fairly rare. Tax Court cases overall are fairly rare. I think there are something like 80,000 notices of objection filed each and every year by taxpayers who dispute what the CRA has suggested is the right answer, from a tax perspective. I think, in total, there's something like only 3,400 Tax Court cases in progress right now. They can take many years, and very few of them are criminal in nature.
On May 3rd, 2016. See this statement in context.