When a Minister uses an alternative audit method, what is the burden of proof?
Canada (Federal), Canada
The following excerpt is from 9091-2239 Québec Inc. v. The Queen, 2016 TCC 198 (CanLII):
These principles also apply when the Minister uses an alternative audit method. In Landry v. The Queen, 2009 TCC 399 (CanLII), 2009 DTC 1359, Justice Hogan, who was dealing with another alternative method, namely, the net worth method, noted the following with regard to the burden of proof:
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