Justice Bocock further found that to pierce the veil of solicitor -
client agency, at such a late stage in the settlement process, would: (i) prejudice the Crown, (ii)
undermine the reliability of s. 169 (3) and related sections of the Rules
for future litigants and (iii) ignore the otherwise more contained and proximate remedies available to a taxpayer where counsel acts to bind the taxpayer without authorization.