Morrison – Federal Court of Canada finds that CRA appropriately denied s. 163(1) penalty relief for failure to notice the accountant’s T4 omission

The taxpayer's accountant inexplicably failed to include a T4 for $47,770 in the taxpayer’s return. In confirming that CRA’s decision to deny penalty relief was reasonable, Campbell J indicated that CRA had appropriately focused on the taxpayer’s “responsibility to exercise care to ensure that all income was reported, and to supply evidence that he was prevented from doing so.” It thus is generally incumbent on the taxpayer to review the return (see also Chiasson).

Neal Armstrong. Summary of Morrison v. Canada (Attorney General), 2018 FC 141 under s. 220(3.1).