The appellant brought a motion to strike out certain paragraphs of the Reply to the Notice of Appeal in two separate appeals concerning assessments for director liability under the Excise Tax Act.
The Minister alleged the appellant was a de facto director and participated in a scheme to avoid tax liabilities.
The Tax Court of Canada granted the motion in part, striking out paragraphs that contained irrelevant facts and conclusions of law, but leaving allegations concerning the alleged scheme and third parties to be determined by the trial judge.
