In preparing the taxpayer's return, the taxpayer's accountant erroneously reported the taxpayer's share of a capital gain as $71,139.42 rather than $711,394.25.
Before going on to find that the taxpayer had made a misrepresentation attributable to neglect or carelessness, Heald D.J. rejected the view that a number reached through a mathematical calculation is not a fact and, therefore, cannot constitute a misrepresentation. He instead accepted the Crown's submission (at p. 6049) that "any incorrect statement amounts to a 'misrepresentation'".