In the recent decision in Simard v. Canada (2015 TCC 2), the Tax Court of Canada made a rare award of costs on solicitor-client basis due to the fact that the Crown had made a number of unfounded allegations of a criminal matter in its Reply which caused the appellant to incur unnecessary costs. The court stated in its reasons: “I have found the pleadings in paragraph 76 of the reply to the notice of appeal scandalous.” A copy of the court’s decision is available here.