Federal Court

Taxpayer’s own arguments confirmed that his application was premature

Tax - Income tax - Residence in Canada

No unfairness arose by making each plaintiff responsible for payment of full costs award

Civil Practice and Procedure - Costs - Scale and quantum of costs

Applicant failed to demonstrate that appeal had reasonable chance of success

Pensions - Federal and provincial pension plans - Federal pension plans

Taxpayer failed to declare that he had common law spouse

Tax - Income tax - Other income

Reasonable for CRA not to grant waiver of penalty for late filing of same form two years in row

Tax - Income tax - Administration and enforcement

Fraud alone wasn’t sufficient to make it unreasonable to deny relief

Tax - Income tax - Administration and enforcement