The Crown brought motions for leave to amend its pleadings to add a sham argument and for security for costs in two consolidated appeals concerning the validity of limited partnerships.
The Tax Court of Canada granted the motion to amend, finding it would assist in determining the real question in controversy and that any prejudice was compensable in costs.
The Court dismissed the motion for security for costs, holding that the Rules only permit such an order where the appellant appears to be resident outside of Canada, which was not the case here.
