Law360 Canada ( October 29, 2026, 9:45 AM EDT) -- Appeal by Minister of National Revenue (Minister) from decision refusing an order compelling Zeifmans to comply with a requirement issued under the Income Tax Act. The requirement sought information and documents relating to named clients and unnamed connected entities. The Minister maintained that prior judicial authorization was unnecessary but Zeifmans disagreed. In earlier judicial review, the issuance of the requirement without authorization was upheld as reasonable. After Zeifmans refused production, the Minister applied for a compliance order. The Federal Court treated the compliance proceeding as de novo with materially different evidence. It found that unnamed persons were under audit, a purpose of the requirement was to further those audits, authorization was required and re-litigation was not an abuse of process. The Minister submitted that a primary purpose of auditing named persons made authorization unnecessary. The test focused on intended use rather than audit status, the evidence established only a named-person audit purpose, and re-litigation was abusive. Zeifmans submitted that the Federal Court correctly interpreted the provisions and made factual findings, and that the earlier reasonableness determinations were not binding. It also maintained that the requirement was vague, invalidly issued to a partnership and should be refused through residual discretion. The parties agreed to $5,000 appeal costs. The Minister sought reversal of the Federal Court costs, although the separate quantification order was not appealed....