Tax Court Accounting Support Case Studies

6 Tax Court Accounting Support tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to tax court accounting support work, not a general example.

Case Study 1 · Backlog brought current

6 Years Filed, $46,000 Removed From The Assessed Balance — Importer Under a Customs, Brampton

Client: An importer under a customs and GST audit  ·  Where: Brampton, Ontario  ·  Engagement: 4 weeks, fixed fee

Years filed6
Assessed balance removed$46,000
CollectionsStopped

The situation

An importer under a customs and GST audit in Brampton, Ontario had not filed for 6 years. The CRA had issued arbitrary assessments, and the business was carrying a proposal letter with a 30-day response window and no supporting records assembled on top of a growing interest balance.

What we did

We started with the oldest year and worked forward so each year's closing balances fed the next. We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely, filing the years in sequence rather than all at once.

The result

Every year is now filed and assessed on actual figures. The notional assessments were vacated and $46,000 of the estimated balance came off, with a payment arrangement covering the rest.

Case Study 2 · Cash and remittance control

Instalments Rebased, $149,000 Of Cash Returned To The Business — Contractor Facing a Proposed, Ottawa

Client: A contractor facing a proposed reassessment  ·  Where: Ottawa, Ontario  ·  Engagement: 10 weeks, fixed fee

Cash returned$149,000
Instalment basisCurrent year
ReviewedQuarterly

The situation

A contractor facing a proposed reassessment in Ottawa, Ontario was paying instalments calculated on a prior year that no longer reflected the business. An objection deadline that had passed with no extension applied for was tying up $149,000 of cash.

What we did

We rebased the instalments on the current-year estimate rather than the prior-year default, and brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action.

The result

$149,000 of cash stayed in the business, the penalty cycle ended, and the instalment position is reviewed each quarter against actual results.

Case Study 3 · Sale and succession

Share Sale Restructured, $690,000 Less Tax On Closing — Corporation Under a GST/HST, Kelowna

Client: A corporation under a GST/HST review  ·  Where: Kelowna, British Columbia  ·  Engagement: 10 weeks, fixed fee

Tax saved on closing$690,000
PriceAs agreed
Post-closing adjustmentsNone

The situation

A corporation under a GST/HST review in Kelowna, British Columbia was preparing to sell. Due diligence surfaced a single shareholder holding every share, with no room to multiply the exemption, which would have reduced the price or killed the deal outright.

What we did

We cleaned up the historical file, assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn, and prepared the due-diligence package the buyer's advisers actually asked for.

The result

The deal closed at the agreed price. $690,000 of tax was saved against the structure originally proposed, with no post-closing adjustment.

Case Study 4 · Records and systems rebuilt

22 Months Reconciled And $19,500 Of Input Tax Recovered — Professional Under a Lifestyle, Regina

Client: A professional under a lifestyle audit  ·  Where: Regina, Saskatchewan  ·  Engagement: 8 weeks, fixed fee

Months reconciled22
Input tax recovered$19,500
Close time7 days

The situation

A professional under a lifestyle audit in Regina, Saskatchewan was carrying a net-worth assessment built on unexplained deposits that were actually loan proceeds. Nothing reconciled, and every filing started with 22 months of cleanup.

What we did

We rebuilt from source rather than correcting on top of the existing file. We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly, then set the routine that keeps it clean.

The result

22 months reconciled to the bank. The close now takes 7 days, and $19,500 of previously unclaimable input tax was recovered in the process.

Case Study 5 · Missed incentive claimed

Incentive Review Recovered $80,000 Across 5 Open Years — Taxpayer with Frozen Bank, Winnipeg

Client: A taxpayer with frozen bank accounts  ·  Where: Winnipeg, Manitoba  ·  Engagement: 8 weeks, fixed fee

Recovered$80,000
Open years claimed5
Ongoing trackingIn place

The situation

An incentive review at a taxpayer with frozen bank accounts in Winnipeg, Manitoba started from a simple question: what has never been claimed? The answer ran to 5 years, driven by a proposal letter with a 30-day response window and no supporting records assembled.

What we did

We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely, documenting eligibility to the standard a reviewer would apply rather than the standard a claim form requires.

The result

The credits produced $80,000 across the open years, and the tracking now in place means the following year's claim is documented as the work happens rather than reconstructed afterwards.

Case Study 6 · Deadline rescue

6-Week Turnaround Beat The Deadline And Saved $48,000 — Restaurant Under a Net-Worth, Guelph

Client: A restaurant under a net-worth audit  ·  Where: Guelph, Ontario  ·  Engagement: 6 weeks, fixed fee

Late-filing penalty avoided$48,000
Filed with19 days to spare
Next yearPapers ready

The situation

With the deadline for tax court accounting support weeks away, a restaurant under a net-worth audit in Guelph, Ontario was carrying a proposal letter with a 30-day response window and no supporting records assembled. The exposure if the date slipped was around $48,000.

What we did

We brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action. The filing went in complete rather than provisional, so there was no amended return to follow.

The result

Filed with 19 days to spare. $48,000 in late-filing penalties avoided, and the working papers are ready for the following year.

Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.

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