If you appeal a Canadian income tax dispute with CRA (the tax department) to the Tax Court of Canada and lose, a further appeal to the Federal Court of Appeal is available.
"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."