Loba Limited v. Canada (National Revenue)

Loba Limited v. Canada (National Revenue)

The court dismissed the Minister's motion to quash because it was not persuaded the appellant acted in bad faith nor that the appeal was vexatious or devoid of substance; the court declined to decide res judicata on the preliminary motion and directed the appeal proceed to be heard on the merits, ordered costs in...

Source-derived case information.

Citation
2007 FCA 37
Parties
Appellant: Loba Limited; Respondent: Minister of National Revenue
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
7 February 2007
Procedural Posture
Appeal (federal Court of Appeal) / Preliminary Motion Stage Minister's Motion to Quash Dismissed; Appeal to Proceed to Merits
Outcome
Motion to quash dismissed; appeal to be heard on its merits
Legal Topics
Res Judicata, Vexatious Proceedings, Costs, Production of Documents, Federal Courts Rules, Rule 317
Source Language
en
Administrative Law Tax Law Civil Procedure Res Judicata Vexatious Proceedings Costs Production of Documents Federal Courts Rules, Rule 317

Source-derived case record

Summary, issues, holding and outcome

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Parties

Loba Limited

Appellant

Minister of National Revenue

Respondent

Procedural Posture

Appeal (federal Court of Appeal) / Preliminary Motion Stage Minister's Motion to Quash Dismissed; Appeal to Proceed to Merits

  1. 1 Whether the appellant acted in bad faith in bringing the appeal
  2. 2 Whether the appeal was vexatious or devoid of any substance
  3. 3 Whether the issue is res judicata

Ratio Decidendi

The court dismissed the Minister's motion to quash because it was not persuaded the appellant acted in bad faith nor that the appeal was vexatious or devoid of substance; the court declined to decide res judicata on the preliminary motion and directed the appeal proceed to be heard on the merits, ordered costs in the cause and directed the Minister to comply with Rule 317 within 45 days.

Court Disposition

Motion to quash dismissed; appeal to be heard on its merits

Orders

  • Motion to quash dismissed
  • Costs to be in the cause