The Respondent brought a motion to strike portions of the Appellant's Notice of Appeal relating to the 2010-2013 taxation years.
The disputed paragraphs alleged that the Minister failed to provide a bank account working paper in a timely manner, which the Appellant argued prejudiced his ability to defend against net worth reassessments.
The Tax Court of Canada granted the motion to strike without leave to amend, holding that the allegations related purely to the Minister's conduct during the audit, which does not go to the correctness or validity of the reassessments and is beyond the Court's jurisdiction.
