evidential burden

By services, 24 August, 2025

At the hearing of the taxpayer's appeal of net worth assessments, the Crown agreed that it would present its case first, given that all the years were statute-barred. At the conclusion of the Crown's evidence, the taxpayer moved to have the appeal summarily allowed on the basis that the Crown's evidence was insufficient to discharge its burden of proving a misrepresentation sufficient to open up any of the years in issue.