Rivard c. Le Roi

Rivard c. Le Roi

Counsel Iezzoni and Gagnon, having been the counsel of record and having not sought or obtained a formal cessation of representation or informed the Court they would not attend after their late adjournment request was denied, breached their professional obligations and engaged in unacceptable conduct that caused the...

Source-derived case information.

Citation
2026 CCI 8
Parties
Applicant/reqûérant: Benoit Rivard; Respondent/intimé: Sa Majesté le Roi
Court
Tax Court of Canada
Jurisdiction
Canada
Judgment Date
13 January 2026
Procedural Posture
Application for Extension of Time to File Notice of Objection (tax) / Costs Determination/order Following Hearing and Case Management Conference
Outcome
Respondent's request for costs granted in part; counsel personally ordered to pay costs of $625 to the Crown within 30 days; counsel prohibited from seeking reimbursement of that amount from the client.
Legal Topics
Extension of Time, Costs, Sanctions Against Counsel, Failure to Appear, Cessation of Representation
Source Language
french
Income Tax Court Procedure Professional Responsibility of Counsel Extension of Time Costs Sanctions Against Counsel Failure to Appear Cessation of Representation

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Parties

Benoit Rivard

Applicant/reqûérant

Sa Majesté le Roi

Respondent/intimé

Procedural Posture

Application for Extension of Time to File Notice of Objection (tax) / Costs Determination/order Following Hearing and Case Management Conference

  1. 1 Whether counsel should be personally ordered to pay costs for failing to appear at the scheduled hearing
  2. 2 Whether counsel breached their professional obligations to client and the Court
  3. 3 What quantum of costs is appropriate under the Rules and the Court's inherent jurisdiction

Ratio Decidendi

Counsel Iezzoni and Gagnon, having been the counsel of record and having not sought or obtained a formal cessation of representation or informed the Court they would not attend after their late adjournment request was denied, breached their professional obligations and engaged in unacceptable conduct that caused the respondent to incur costs; under Rule 152 and the Court's inherent jurisdiction the appropriate sanction is an order that counsel personally pay costs in the amount prescribed by Article 11 of the informal rules, namely $625, payable to the Crown within 30 days; that amount must not be recovered from the client.

Court Disposition

Respondent's request for costs granted in part; counsel personally ordered to pay costs of $625 to the Crown within 30 days; counsel prohibited from seeking reimbursement of that amount from the client.

Orders

  • Counsel Avocats I.G.M. s.e.n.c., namely Mes Franco Iezzoni and Lise A. Gagnon, are ordered to pay costs of $625 to Her Majesty the King within 30 days of the date of the order.
  • Counsel are personally liable for the payment and may not seek reimbursement of this sum from their client, Benoit Rivard.