Robert Cormier
I "kinda" like this David Smile - To the extent the Plaintiff can in future frame his action and plead material facts that do give rise to a known cause of action and issues upon which the Court can adjudicate, he is free to bring his claim at that time. With respect to his immediate dispute with CRA, if it is available and subject to the provisions of the Income Tax Act, the Plaintiff may be able seek or pursue whatever relief or course of appeal that is provided under the legislation. <---Seems like you ALMOST nailed it. :)