Yes, that has been my experience by far. From a tax perspective, I think very few cases actually go to court.
The Income Tax Act, like all law, is subject to interpretation, and there can be two sides to a story. When I advise clients, I know that from a client perspective they will often try to settle without going to court. It depends on their risk tolerance, but it is always subject to interpretation. Even if they feel they have a very solid case under the tax law, there is always some uncertainty. Court cases are very expensive, lawyers are very expensive, and there is some uncertainty. It can take up to a decade for a tax matter to go through the courts.
From CRA's perspective—I don't know, but I would imagine—if they can create certainty, if they can get a timely settlement so they can take their resources and move them to other files, I am sure that is what is driving their behaviour. If there are 80,000 formal notices of objection a year filed by Canadians because there is a dispute between what the taxpayer thinks is right and what the CRA asserts is right, and if there are only 3,400 cases in the courts, settlements happen routinely and daily.