Canada (Attorney General) v. Villeneuve, 2004 DTC 6576, 2004 FCA 20 -- summary under Subsection 163(2)

By services, 28 November, 2015

The taxpayers received substantial tax refunds by misrepresenting that they were married (when they were not) or that they had dependants (when they did not) as a result of conniving with an Agency employee, who allowed the refund claims and received a rebate from the taxpayers of two-thirds of the refunds received by them.

Such conduct was found to be willful blindness and, consequently, gross negligence.

Note
followed in Attorney General of Canada v. Savard and Houde, 2004, DTC 6734 2004 FCA 150
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