By Cris Best (January 16, 2023, 2:52 PM EST) -- To appeal a tax assessment, a taxpayer must file a Notice of Appeal with the Tax Court of Canada. The Department of Justice (DOJ), representing the minister of national revenue with Canada Revenue Agency (CRA), will respond with a reply. As per s. 49 of the Tax Court of Canada Rules (General Procedure) (SOR/90-688a) (the Rules), the reply shall, in part, include facts and/or assumptions of fact including relevant facts....