1. Magnum also argued that, since the Minister had placed its claim in abeyance without advising it that it could not claim on behalf of the owner-operators, it would now be unfair to deny the refund claim because, if the appeal were dismissed, the owner-operators would be statute-barred from submitting refund claims themselves.

Le Tribunal prend note qu'aucun élément de preuve n'a été fourni à l'appui de ces affirmations.