The taxpayer's lack of familiarity with Canada's tax system could not by itself support a due diligence defence against s. 163(1) penalties. The fact that he had received two T4s for the second year in question, and had included the full amount for the first T4 in his income, also was not the basis for a due diligence defence, given the materiality of income omitted from his reported income as reflected on the second T4.
Topics and taglines
Tagline
lack of familiarity with Canadian tax - not diligent - magnitude of omission
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
334791
Extra import data
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"field_legacy_header": "<strong><em>Chendrean v. The Queen</em></strong>, 2012 DTC1188 [at 3482], 2012 TCC 205 (Informal Procedure) <strong>[lack of familiarity with Canadian tax - not diligent - magnitude of omission]</strong>",
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