Précis: At discovery Mr. DiLalla had asked for three kinds of documents from the Crown, all of which were refused:
(1) all policies and interpretations of the Canada Revenue Agency that mention or are in relation to personal endeavours and hobbies, (2) all such documents relating to gross negligence penalties, and (3) Canada Revenue Agency’s policies as to whether a net worth audit should be completed.
He appealed that refusal to the Tax Court which declined to order their production on the basis that the requests were overly broad and vague. He appealed the first two categories to the Federal Court of Appeal which dismissed the appeal, with costs, as not disclosing a reviewable error.
DiLalla v. R. – FCA: Decision that production requests overly broad and vague did not disclose reviewable errorPlus >