Précis: The taxpayer brought a motion to strike the Crown’s Reply. The motion was brought almost three years after the Reply was filed and after the completion of a number of additional procedural steps. The Tax Court dismissed the motion and Mr. Dilalla appealed to the Federal Court of Appeal. The Court of Appeal dimissed the appeal with costs holding that the Fresh Step Rule was applicable and had been properly applied by the Tax Court.
Dilalla v. R. – FCA: Court of Appeal denies appeal of application of “Fresh Step” rule by the Tax CourtREAD MORE »