Chapter

(4) Should the Assessment of the Gross Negligence Penalties be Confirmed?

From Deyab v. Canada, 2020 FCA 222 by Sambif

Concepts

1. Penalty Caution

   "In Lacroix, at paragraph 28, this Court quoted the following passage from the decision of Justice Bowman in Farm Business Consultants Inc. v. Her Majesty the Queen, [1994] 2 C.T.C. 2450, 95 D.T.C. 20

2. Corporate Losses

   "In the case that is before us, the Tax Court Judge acknowledged that substantial sums had been transferred by Mr. Deyab to M.D. Consulting. The concern in this case related to the record keeping, and