After finding that the taxpayers did not have limited recourse amounts for promissory notes they gave as consideration for the limited partnership units offered with the offering memoranda given the absence of any arrangements for payment of interest on the notes on a timely basis and other deficiencies, Campbell, J. found (at para. 104) that the taxpayers could not be reassessed beyond the normal reassessment period:
"I believe they were acting in a reasonable and prudent manner in placing reliance on the various professional opinions before making a decision to invest and should not be held to a higher standard. To do so would be to insist that they must personally investigate the technicalities of the various structures and arrangements of public offering documents."