Tax Court of Canada Rules (General Procedure) (SOR/90-688a)

135 (1) If at a hearing a party proposes to adduce evidence, the party or the party’s counsel shall, unless the judge directs otherwise, immediately before adducing the evidence, open his case by making a short statement giving a concise outline of the facts that the party proposes to prove and of the applicable law.

(2) Unless the judge directs otherwise, the parties shall put in their respective cases by evidence or by putting before the Court the facts on which they rely, in the following order,

• (a) the appellant,

• (b) the respondent, and

• (c) the appellant in respect of rebuttal evidence.

(3) Unless the judge directs otherwise, after all parties have adduced their evidence, they shall be heard in argument in the order in which they adduced their evidence and the party who was first heard in argument may reply and an opposing party may answer a new point of law raised in the reply.