What is the impact of the fact that no reliable source records exist justified the Minister's conduct and reassessment under subsection 152(7) of the Criminal Code?
Canada (Federal), Canada
The following excerpt is from Lin v. The Queen, 2020 TCC 26 (CanLII):
The fact that no reliable source records of any kind existed justified the Minister’s conduct and reassessment under subsection 152(7): Malone v. HMQ, 2006 TCC 313.
Similarly, the allocation of shareholder benefits to a taxpayer’s shareholder is justifiable where that benefitting taxpayer is a shareholder: Rancourt v. HMQ, 2005 TCC 709.
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