R. v. Landes, [1988] 1 CTC 124 (Queb. Ct. S.P.) -- summary under Paragraph 239(1)(d)

By services, 28 November, 2015

Although the assumption of the accuseds that their pre-1972 real estate gains were capital gains "may have been illogical, naive, unsophisticated for people with business experience, and based on mere wishful thinking", it could not be said that this position was so untenable as to lead to the conclusion that they were carrying out a deliberate scheme to evade the payment of tax.

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