Itzovitch v. Canada (Attorney General)

Decided: 2026-10-01. Docket: T-3379-25. Citation: 2026 FC 1215 (CanLII). Procedure — Judicial review — Federal Court — Application for judicial review of CRA refusal to waive TFSA overcontribution assessment — Respondent objection to new information not before the decision-maker — Court declines to consider improper record materials — Judicial review framework applied to CRA reconsideration decision — Application for judicial review dismissed | Administrative law — Procedural fairness — Independent decision-maker — Whether CRA delegate delegated responsibilities to the Attorney General of Canada — Decision letter reference to “recommendation” of Department of Justice analysed — Officer’s notes and procedural history reviewed for independent reconsideration — No denial of procedural fairnes