- Parties: The appellant was Keystone RV Company. The respondent was His Majesty the King.

- Subject Matter: The underlying appeal involved a series of reassessments by the Canada Revenue Agency under the Excise Tax Act, 1985 relating to seven monthly GST/HST reporting periods from Jan. 1, 2014 to July 31, 2014, which resulted in the imposition on the appellant of an additional aggregate net GST/HST of $24,695,247.20. The Tax Court of Canada issued an interlocutory decision dismissing the appellant’s motion for judgment on admissions under r. 170.1 of the Tax Court of Canada Rules (General Procedure), SOR/90-688a; granting the respondent’s cross-motion to amend its reply under r. 54 of the Rules; awarding the respondent costs on the r. 170.1 motion; and awarding costs on the r. 54 motion. The appellant appealed the interlocutory decision.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal. The appeal court found no legal error or palpable and overriding error in the Tax Court’s analysis and rejection of the appellant’s r. 170.1 motion. The appeal court disagreed with the appellant’s argument that the respondent’s r. 54 motion was abusive and was an attempt to appeal the Minister’s assessment.

- Date: The hearing was set on Sept. 17, 2024. The court released its decision on Sept. 23, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: The appeal court awarded costs in an unspecified amount.