In MNR v. Lordco Parts Ltd., 2013 FCA 49, the Federal Court of Appeal (FCA) reaffirmed that the Canada Revenue Agency (CRA) has an obligation to make “full and frank disclosure” in any ex parte application for an authorization to issue a third-party requirement under s. 231.2(3). In this case, the CRA failed to meet that obligation when it sought – and obtained – a s. 231.2(3) authorization without disclosing that there existed an alternative source by which the third-party information could be obtained (MNR v. Derakhshani, 2009 FCA190).