Canada (Customs and Revenue Agency) v. Artistic Ideas Inc., 2005 FCA 68 -- summary under Subsection 231.2(1)

The appellant had arranged for the sale of artwork to individual Canadian taxpayers who donated the works to registered charities at a marked-up value. When the Minister issued a requirement to the appellant under s. 231.2(1), the appellant was entitled to redact the name of the third-party taxpayers (donors) given that the Minister was investigating compliance by the taxpayers with the Act. Counsel for the Minister unsuccessfully argued that "the restriction against obtaining information or documents relating to unnamed persons only applies where the third party itself is not under investigation".