The appellant appealed his convictions for failing to file income tax returns, advancing pseudolegal arguments that he was not a 'person' under the Income Tax Act and that paying taxes is voluntary.
The Superior Court of Justice dismissed the appeal, finding the arguments frivolous, vexatious, and devoid of merit.
The court also reprimanded the appellant's counsel for advancing Organized Pseudolegal Commercial Argument (OPCA) theories, noting it was an abuse of the court's process and a breach of professional obligations.