By Dale Barrett ( March 29, 2023, 9:37 AM EDT) -- In the landmark decision of Choptiany v. Canada, [2022] T.C.J. No. 82, the Tax Court of Canada highlighted the significance of procedural compliance, sending a strong message to the Canada Revenue Agency (CRA) and legal professionals alike. While the three taxpayers in question were far from model citizens, the court ultimately sided with them due to the CRA’s serious and repeated procedural non-compliance....