Chaumont v. The Queen, 2010 DTC 1014 [at at 2599], 2009 TCC 493 (Informal Procedure) -- summary under Subparagraph 152(4)(a)(i)

After noting that the taxpayer's submissions as to his exemption under the Canada-France Convention on interest income earned by him from a French source "were unusual and even surprising" (para. 15), and that the taxpayer was taxable on such interest income. Tardiff, J. went on to find (at para. 22) that "the case at bar did not involve stubbornness or capriciousness; rather, it involved a legitimate question and a principled concern that had a modicum of foundation" so that the penalty did not apply.