Anchor Pointe Energy Ltd v. The Queen, 2006 DTC 3365, 2006 TCC 424 -- summary under Onus

The Minister originally had reassessed the taxpayer on the basis that it was entitled to claim a deduction in respect of the fair market value of seismic data equal to the data's fair market value, and then confirmed the notice of reassessment on the basis that the expenditures in question did not qualify as Canadian exploration expense. Bowman C.J. found that the taxpayer did not have the onus of disproving new "assumptions" made by the Minister at the time of issuing the notice of confirmation.