Question juridique clé
Whether the tax authority violated the taxpayers' right to be heard by relying on documents not included in the file list disclosed for inspection.
Solution extraite
Yes. The authority relied on additional decisive documents that had not been disclosed for inspection or adequately summarized to the taxpayers.
Motifs extraits
Access to all case files forming the basis of the decision must be granted even if the materials are thought not to affect the outcome. The taxpayers were entitled to assume that the disclosed file list contained the relevant dossier, and the authority could not later rely on undisclosed documents without complying with the statutory procedure.