What is the test for determining whether or not a person who refuses or fails to conduct an inquiry into their personal tax situation is a tax evasive?
Canada (Federal), Canada
The following excerpt is from Hébert v. The Queen, 2009 TCC 124 (CanLII):
I must also take into account what Nadon J.A. stated in his decision in Panini v. Canada, 2006 FCA 224 (CanLII), at paragraph 43: ". . . the law will impute knowledge to a taxpayer who, in circumstances that dictate or strongly suggest that an inquiry should be made with respect to his or her tax situation, refuses or fails to commence such an inquiry without proper justification."
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