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Motion to consolidate two tax appeals granted due to identity of parties and overlapping evidence.
The appellant brought a motion to consolidate two appeals pursuant to Rule 26 of the Tax Court of Canada Rules (General Procedure).
One appeal concerned the deductibility of expenses, while the other concerned withholding tax and related penalties.
The Tax Court of Canada granted the motion, finding that the identity of the parties and the substantial overlap in evidence justified consolidation to promote efficiency without causing prejudice to the respondent.
