When a Minister resorts to a net worth assessment, what is the burden of proof against the Minister's assessment?
Canada (Federal), Canada
The following excerpt is from Epel v. The Queen, 2003 TCC 707 (CanLII):
When the Minister resorts to a net worth assessment, the assessment is presumed valid and the onus of proof falls on the Appellant to disprove the Minister's calculations (Pal v. Canada, [2002] T.C.J. No. 243 at page 2):
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