I think, Mr. Chair, I'll refer to paragraph 2.33 in that audit. In there we point out that the rate of growth of the number of new objections far outpaced the increase in resources that the agency dedicated to managing them, and that in the past 10 years, the inventory of outstanding income tax objections increased by 171%, while the number of employees dedicated to resolving these objections increased by 14%.
There definitely is a certain component of this that has to do with resourcing, and if you look at exhibit 2.5 in the audit above paragraph 2.76, you'll see things like, in 32% of the cases, it was that the taxpayer had to provide new facts that were not asked for at the assessment or reassessment stage; in 28% of the cases, the information was already on file at the Canada Revenue Agency, but they didn't recognize it at that point in time; and in 8% of the cases, the Canada Revenue Agency improperly applied the facts, the law, or the policy.
Yes, there's a certain component related to resourcing, but I think there are a lot of things that the Canada Revenue Agency can do to improve its process. One of those things would be just learning the lessons from later decisions when one of their assessments or reassessments is overturned, and building that back into their process. I think there's a lot they can do even with the resources they have.