What is the impact of a penalty for failing to properly assess the risk to a taxpayer in a property transaction?

Canada (Federal), Canada

The following excerpt is from Thompson v. The Queen, 2010 TCC 381 (CanLII):

Justice Boyle in Dunlop v. The Queen, 2009 TCC 177, 2009 D.T.C. 650, [2009] 6 C.T.C. 2223 reiterated that the penalty will not apply if the taxpayer “can demonstrate he exercised a requisite degree of due diligence”.

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