Knight v. The Queen, 2012 DTC 1144 [at at 3300], 2012 TCC 118 (Informal Procedure) -- summary under Subsection 163(1)

By services, 28 November, 2015

Jorré J. found that the taxpayer, having no reasonable excuse for his failure to report over $40,000 in salary and severance pay, being nearly half his income for the year, was liable under s. 220(3.1) of the ITA for a penalty of 10% of the unreported income. Although technically outside the Court's jurisdiction, Jorré J. found it likely that the taxpayer was also liable for a further 10% penalty under British Columbia's Income Tax Act. The federal and provincial penalties totaled $8175. However, taxes had already been withheld from the taxpayer's unreported income. The federal and provincial treasury were, at the time of reassessment, out of pocket only $3,874, including interest.

Jorré J. recommended that the taxpayer apply for discretionary relief of penalties, and that his application be treated leniently, given that the taxpayer's penalties were over 200% of the amount of omitted tax. In other words, the taxpayer's penalties would have been considerably lower if his conduct had been more blameworthy - 50% of the omitted amount if there had been gross negligence, and between 50% and 200% if the taxpayer were charged on summary conviction.

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penalties would have been less for more blameworthy conduct
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