Rawlings - AI-assisted individual successfully seeks judicial review of CRA refusal to let him refile a return from before the normal reassessment period

In 2005, the taxpayer filed an amended return for his 2004 that almost doubled his reported income for 2004. This was a mistake, (which he attributed to confusion resulting in part from a debilitating car accident he had suffered years before) and in 2011, he filed a further amendment, seeking to reverse the additional income inclusion, which CRA disallowed.

In 2022, the Tax Court ruled that it had no jurisdiction to require CRA to accept an amended return. In February 2023, the taxpayer again requested the amendment to his 2004 return. Although the request was submitted on the form used to request a waiver of interest, his written explanation indicated that his request was solely for CRA to allow an amendment to his 2004 tax return, as per his 2011 request.

CRA treated this as an application for relief from arrears interest, and denied that request.

The taxpayer “was unrepresented and had relied heavily on artificial intelligence to prepare his case” before Brouer J. Before referring the matter back to CRA for redetermination, Brouer J stated (at para. 21):

… Mr. Rawlings was entitled to a justified, intelligible and transparent decision that responded directly to his request, which he first made in 2011 and has continued to seek ever since. The decision under review does not meet this standard and is therefore unreasonable.

Neal Armstrong. Summary of Rawlings v. Canada (Attorney General), 2026 FC 208 under s. 152(4.2).