Pontarini v. The Queen, 2009 DTC 1462, 2009 TCC 395 -- summary under Subsection 163(2)

Penalties were applicable to a doctor who, rather than providing to his accountant financial statements prepared by his medical clinic, prepared his own statements that significantly understated revenues and overstated expenses. Although he had a difficult and troubled personality, "there was no credible evidence of a material, physical or mental health illness, condition or treatment that interfered with [his] ability to comprehend or reason ..." (para. 26).