Concept
Tax Court
Deyab v. Canada, 2020 FCA 222 / C. The Application of Lacroix
"I agree with Mr. Deyab that the Tax Court Judge erred in applying this Court’s decision in Lacroix to the facts of this case. It is evident from reading the Tax Court Judge’s reasons that he effectively addressed the issues of whether the Minister could reassess the statute-barred years and whether gross negligence penalties could be assessed collectively. He concluded, as noted in the excerpt from the oral reasons quoted at paragraph 16 above, that “the Minister has satisfied her onus under both subsections 152(4) and 163(2) of the Act”."
Related Ideas
- Gross NegligenceDeyab v. Canada, 2020 FCA 222 · II. Decision of the Tax Court
- Penalty TestDeyab v. Canada, 2020 FCA 222 · (3) The Tax Court Judge’s Errors
- Distinct RequirementsDeyab v. Canada, 2020 FCA 222 · (1) The Decisions of this Court and the Tax Court in Lacroix
- Reassessment RequirementsDeyab v. Canada, 2020 FCA 222 · (2) Gross Negligence Penalties versus Reassessing a Statute-barred Year
- Gross NegligenceDeyab v. Canada, 2020 FCA 222 · (2) Gross Negligence Penalties versus Reassessing a Statute-barred Year
- Penalty CautionDeyab v. Canada, 2020 FCA 222 · (4) Should the Assessment of the Gross Negligence Penalties be Confirmed?
- Lacroix FindingsDeyab v. Canada, 2020 FCA 222 · (1) The Decisions of this Court and the Tax Court in Lacroix
- Deyab ComparisonDeyab v. Canada, 2020 FCA 222 · (1) The Decisions of this Court and the Tax Court in Lacroix