The short answer is a resounding NO. This is baked into the law. For example, 299(3) of the Excise Tax Act states: “An assessment, subject to being vacated on an objection or appeal under this Part and subject to a reassessment, shall be deemed to be valid and binding.” What this means is that for the purposes of an appeal, the onus is on the taxpayer to “demolish” the CRA’s assessment with facts and evidence to the contrary. It’s not impossible and many times the Appeals officer may even suggest the facts and evidence that could result in the assessment being vacated or reassessed in whole or in part, but it’s by no means required of the Appeals officer and will require you or your representative to present your facts and evidence in a way that allows the Appeals officer to reassess the tax owing in your favour. A retired CRA insider from any taxpayer facing position like Appeals, Audit, and Rulings, intimately knows the required facts and evidence and the format to present it to the Appeals officer so that it is easy for them to reassess in your favour. The way to think of this is, that money is already gone unless you present your case correctly, and the easiest, most reliable, and affordable way is to employ a ZheroTax expert on a contingency basis to manage your appeal.