Health Quest - CRA loses in the Tax Court of Canada because Justice pleaded a legal conclusion

After pleading that some of the taxpayer's supplies of footwear were zero-rated as they were specially modified or designed for people with disabilities, the Justice lawyer then simply pleaded an assumption that the sales which CRA had assessed were not zero-rated.  As this "assumption" was one of mixed fact and law, its pleading did not shift the burden of proof away from the Crown, so that it lost.

Neal Armstrong.  Summaries of Health Quest Inc. v. The Queen, 2014 TCC 211 under General Concepts - Onus and ETA - Sch VI - part II - s. 24.1.