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The Tax Court held UDP donation receipts lacked prescribed information under Regulation 3501, so the claimed charitable gifts were not eligible under subsection 118.1(2).
The application under s.58(1)(a) was dismissed because the Proposed Question was not properly raised by the pleadings and could not be said to have a reasonable chance of disposing of the proceedings, shortening the hearing, or saving costs; vacatur of determinations is limited to findings that determinations are invalid or incorrect and challenging potential future reassessments is not a proper use of s.58.
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