A taxpayer may request relief on a prescribed form or may elect use a letter instead provided the points raised on the form are all covered by the letter. If the request is denied, a taxpayer could request a second review, which will be done by a higher rank official. If the request is still denied, a taxpayer could request a judicial review of the decision in the federal court, not tax court. The federal court will determine whether CRA exercises its discretion reasonably. If not, the court will send the file back to the CRA for reconsideration. The court rarely will make a decision for CRA because the discretion is with CRA and not the court. If a taxpayer is not happy with the judicial decision, they can pursue an appeal at the Federal Court of Appeals.