In 145257 Ontario Inc. v. The Queen, 2015 DTC 1160 (TCC), Lyons J found that a dissolved corporation incorporated under the Ontario Business Corporations Act (the “OBCA”) must be revived before it can carry on a tax appeal. Though the Federal Court of Appeal had previously ruled in The Queen v. Sarraf 94 DTC 6229 (FCA) that the OBCA permitted a dissolved corporate taxpayer to appeal a tax assessment, Lyons J determined that subsequent amendments to the OBCA  have eliminated this ability.