Hafizy v. Canada (National Revenue), 2014 FCA 109, aff'g 2012 DTC 1093 [at 2943], 2012 TCC 56 -- summary under Subsection 180(3)

By services, 28 November, 2015

In affirming the trial judge's findings that the taxpayers' documentation was inadequate to support their purported cash expenses (see summary under General Concepts - Evidence), Gauthier JA stated (at para. 11):

As Stratas JA explained in Canada v. South Yukon Forset Corporation, 2012 FCA 164 at paragraph 46, "[w]hen arguing palpable and overriding error, it is not enough to pull at leaves and branches and leave the tree standing. The entire tree must fall. Here, ... at least one of the judge's references appears to be factually incorrect if read literally... . That being said, the tree has not fallen.

Topics and taglines
Topic
Income Tax Act - s. 180(3)
Tagline
tree must fall under palpable error standard
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
335849
Extra import data
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