Question juridique clé
Whether the complaint concerning direct federal tax was admissible and well-founded, including the challenge to the non-entry decision.
Solution extraite
The complaint was admissible only to a limited extent; the challenge to tax forgiveness was outside the subject matter and, in any event, not amenable to this remedy. The non-entry decision on the federal tax objection was otherwise upheld.
Motifs extraits
The taxpayer's alleged business losses were only vaguely asserted and unsupported by documents, so the tax authority could lawfully treat the objection as lacking a sufficient legal interest beyond the requests actually raised.