O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295 -- summary under Subsection 163(2)

By services, 28 November, 2015

The two principals of a limited partnership tax shelter were assessed gross negligence penalties. In vacating the assessments, Campbell, J. stated (at para. 113) that "although their suspicions should have been raised based on their business background, the conduct does not meet the requisite threshold of reprehensible recklessness".

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