What grounds have been established for wilful blindness under the Taxation and Statistics Act?

Canada (Federal), Canada

The following excerpt is from Smith v. The Queen, 2019 TCC 274 (CanLII):

In short, the Minister identifies these omissions as grounds comprising wilful blindness. The Minister asserts this is wilful blindness to a degree that rises to gross negligence or is a cavalier disregard to complying with obligations under the Act to verify the accuracy of the returns: Lauzon v. HMQ, 2016 TCC 71 at paragraphs 42, 43 and 44.

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