Chapter

A. Burden of Proof

From Deyab v. Canada, 2020 FCA 222 by Sambif

Concepts

  1. Burden Proof

    "Mr. Deyab’s argument that the Tax Court Judge inappropriately shifted the burden of proof to Mr. Deyab, in relation to the reassessments of the statute-barred years, arises from the sequence in which

  2. Loan Records

    "It is clear from the evidence that was presented at the hearing that there is no dispute that Mr. Deyab withdrew the amounts in question from M.D. Consulting during the taxation years in issue. There

  3. Source Evidence

    "In this case, there is also a problem in identifying the source of the amounts that were transferred to Mr. Deyab and his family during the years in question. This is best illustrated by the summary

  4. Tax Liability

    "As a result, while the Tax Court Judge should have first acknowledged that the onus was on the Minister to establish the facts that would justify the reassessments issued for the statute-barred years

A. Burden of Proof | Deyab v. Canada, 2020 FCA 222 | Bifalgorithm | Bifalgorithm