A couple of recent cases in the Federal Court of Appeal (“FCA”), which saw the taxpayer and importer, respectively, attempting to appeal earlier Court decisions, have emphasized that tax and trade litigation is a “one-shot deal”, where taxpayers (and importers on the trade side) are required to put their best foot forward in the lower Courts, and will be unlikely to get a second chance at making arguments before the FCA (or the lower Courts) if they do not do so.
Doostyar v. Canada
Doostyar v. Canada was a tax case, appealed to the FCA, in which the taxpayer’s position was that the Tax Court of Canada (“TCC”) erred by not accepting its additional submissions, post hearing.
Tagged in:
Federal Court of Appeal
Notice of Appeal
Reassessment of Evidence
Tax Court of Canada
Taxpayer
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