Dalphond v. The Queen, 2009 DTC 1395, 2008 TCC 427, aff'd 2010 DTC 5016 [at 6589], 2009 FCA 121 -- summary under Subparagraph 152(4)(a)(i)

By services, 28 November, 2015

The taxpayer, who had retired from a long career of managing pension funds (and, therefore, was considered to be sophisticated), made a misrepresentation attributable to neglect when he claimed the enhanced capital gains disposition with respect to a sale by him of shares of a corporation which was controlled by non-residents (a fact of which he professed to be unaware) at a time that was less than two years from the date of his acquisition of the shares. A simple check would have enabled him to see that the disposition did not qualify.

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sophisticated taxpayer failed to seek advice
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
334535
Extra import data
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