The appellants, who participated in the Global Learning Gifting Initiative tax shelter, brought motions to have their appeals allowed on the basis of abuse of process.
They alleged that the Minister of National Revenue intentionally delayed confirming objections and engaged in a 'divide and conquer' strategy to wear down taxpayers.
The Tax Court of Canada dismissed the motions, finding that the Minister's slow pace in processing objections and other complained-of conduct did not amount to an abuse of the Court's process in the appellants' specific appeals.