DesRoches v. Canada

Decided: 2026-09-28. Docket: A-422-24. Citation: 2026 FCA 161 (CanLII). Taxation — Excise Tax Act appeals — Notice of objection — Assessments for reporting periods — Whether appeal could proceed without a valid notice of objection — Minister’s preliminary motion to quash — Tax Court held appeal not properly before it — Appeal dismissed with costs | Administrative law — Procedural fairness — Tax Court informal procedure — Whether taxpayer was afforded opportunity to present evidence and make representations — Tax Court allowed further evidence after close of evidence — Subsection 18.15(3) of the Tax Court of Canada Act applied — Proceedings fair in all circumstances — Appeal dismissed | Evidence — Assessment of evidence — Mailing of notice of objection — Whether Tax Court misapprehended evi