Does the absence of due diligence by accountants or bookkeepers disentitle a taxpayer to relief envisaged in the Pillar Oilfield case?

In Roberts v. Canada, [1997] T.C.J. No. 771, Bowman J. said: Here it is true the appellant hired bookkeepers for one of the periods in question and paid them what appears to me to be excessive amounts for their incompetence and inaction. This might justify an action by the appellant against them, but it does not amount to due diligence. The accountants are after all the appellant's agents and the appellant is responsible of what they did or failed to do. In the same way as the exercise of due diligence on the part of a taxpayer's accountants or bookkeepers would be attributed to the taxpayer and would justify the removal of a penalty, so too does the absence of due diligence on the part of the taxpayer's accountants or bookkeepers disentitle him or her to the relief envisaged by the Pillar Oilfield case.