Richer v. The Queen, 2009 DTC 1413, 2009 TCC 394 -- summary under Subsection 163(2)

After finding that the debt forgiveness rules applied to the taxpayer contrary to the taxpayer's reporting of a transaction in which a claim against him was settled, Jorré, J. noted that the taxpayer was convinced in his own mind that he could not owe anything to the party in question other than what he paid on the settlement of the claim (so that there was no forgiveness in the taxpayer's mind) and that "failing to apply the debt forgiveness provisions is rather different in nature from failing to include, say, gross rents in the computation of rental income") (footnote 64). Accordingly, the taxpayer was not grossly negligent.