In Kaiser v. Canada (Minister of National Revenue – MNR), [1995] F.C.J. No. 349 (F.C.T.D.), Rouleau J. noted that the purpose of the fairness provisions is to give the Minister of National Revenue a discretionary power to waive or cancel all or any portion of any penalty or interest when exceptional circumstances or circumstances beyond the taxpayer’s control prevent him or her from meeting deadlines or complying with the rules under the tax system.
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