The appellant, who suffers from bipolar affective disorder, represented himself in multiple income tax appeals.
After numerous adjournments due to his mental health, the Court held a status hearing to determine if he was under a legal disability pursuant to section 29.1 of the Tax Court of Canada Rules.
Finding that it lacked sufficient medical evidence to make a final determination but had implied jurisdiction to manage its process, the Court ordered the respondent's counsel to notify the Public Guardian and Trustee of British Columbia to initiate a formal capability assessment.