Blier c. La Reine, 2003 TCC 505 (Informal Procedure), briefly aff'd 2004 DTC 6726, 2004 FCA 236 -- summary under Subsection 237.1(7.4)

Before finding that the appellants, who clearly had promoted what was a tax shelter given that investor paid 32% of the amount invested and deducted the full amount invested as a business loss, had not exercised due diligence for the purposes of avoiding the penalty under s. 162(9) (which since had been repealed and replaced by s. 237.1(7.4)), Lamarre Proulx J. noted that "financial planners have an important role in economic life ... . They must personally ensure that the investments they propose are legal and must exercise the required diligence with respect to the substantial investments that they propose to their clients".