Précis: The Crown moved to quash the appeals of Ms. Abdalla and 26 other taxpayers on the basis that each of them had executed an Agreement to be Bound and Waiver of Objection and Appeal Rights (the “Waiver”) in respect of a lead appeal known as Mariano v. The Queen, 2015 TCC 244. In Mariano the Court found that the donation plan at issue was a sham and dismissed the appeal. In Abdalla the taxpayers argued that the Waiver was ineffective for a variety of reasons. The Court rejected the various reasons proffered by the taxpayers and quashed their appeals, with costs to the Crown.
Abdalla v. R. – TCC: Tax Court declines to set aside waiversREAD MORE »