Simon's Legal Resources

Reasons - Tax

. Malone v. Canada

In Malone v. Canada (Fed CA, 2026) the Federal Court of Appeal considered the adequacy of reasons for decision, here in a tax appeal context:

[13] Finally, the Tax Court’s reasons were sufficient. The issues and the analysis are clearly and comprehensively laid out and summarized (TC Reasons at para. 36), providing a meaningful basis for appellate review: R. v. Sheppard, 2025 SCC 29 at para. 45 [Sheppard 2025], citing Sheppard 2002 at para. 42. The logical connection between "“what”" was decided and "“why”" it was decided is apparent: R. v. R.E.M., 2008 SCC 51 [R.E.M.] at para. 17.

[14] Reasons need not describe every piece of evidence or every argument made by each party: Hennessey v. Canada, 2016 FCA 180 at para. 10, and must be read together with the record, the parties’ submissions, and the history of the case: Sheppard 2025 at para. 46, citing R.E.M. at para. 17; Dnow Canada ULC v. Grenke Estate, 2020 FCA 61 at para. 21. With due regard to the record, there are no concerns with the adequacy of the Tax Court’s reasons.