http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/110639/index.do 
1455257 Ontario Inc. v. The Queen (July 7, 2015 – 2015 TCC 173, Lyons J.).
Précis: The taxpayer was an Ontario corporation that was dissolved in 2007. On October 18, 2010, it was assessed pursuant to section 160 of the
Income Tax Act (the “
Act”) relating to the tax indebtedness of 1473661 Ontario Limited (presumably a related corporation) as at that date. The Crown moved to compel the taxpayer to take steps to revive its corporate status within 30 days. The taxpayer argued that a revival was not necessary. The Court disagreed, allowed the motion and awarded costs to the Crown.
Decision: Although there was some ambiguity in the jurisprudence, the Court held that the taxpayer could not continue its appeal without reviving its corporate status:
[36] I find that upon dissolution in 2007, 1455257 ceased to exist. To cure that impediment, 1455257 needs to be resuscitated and unless and until it is revived by virtue of subsection 241(5) of the OBCA it lacks capacity to pursue or defend the appeal. Thus upon revival 1455257 "shall be deemed for all purposes to have never been dissolved”.
[37] Whilst it may be inconvenient for 1455257 to revive, I find it is necessary to revive its corporate capacity which 1455257 had the ability to do at the time the assessment had issued against it in 2010. Upon revival, 1455257 will be restored to its legal position and “shall be deemed for all purposes to have never been dissolved” pursuant to subsection 241(5). In my view this validates the bringing of the appeal and all consequential steps; inherent in that is 1455257’s ability to defend itself.
[38] In view of my finding, it is unnecessary to consider the remaining issues.
[39] The respondent’s motion is allowed. The appeal is adjourned for 60 days from the date of this Order to allow 1455257 to take steps to revive its corporate status pursuant to subsection 241(5) of the OBCA.
[40] Costs are awarded to the respondent in the event.