Harvey v. The Queen, 2013 TCC 298 -- summary under Subsection 163(2)

By services, 28 November, 2015

Graham J found (citing Raposo) that the taxpayer's guilty plea under s. 239 for failing to report commission income from his real estate business was prima facie proof that he had also been grossly negligent for purposes of s. 163(2) (para. 25). It was not necessary to dispose of the taxpayer's argument that in the other action he had thought he was only pleading guilty to having been negligent, as in this action the Crown had established that the taxpayer had falsified statements of his commission income before providing them to his tax preparer. The taxpayer's appeal was denied in respect of the penalties.

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guilty plea is prima facie proof of income from tax evasion
d7 import status
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Node
Drupal 7 entity ID
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Extra import data
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