Agence du revenu du Québec v. Stamatopoulos, 2018 QCCA 474

ARQ failed to establish that a named supplier to the taxpayer did not act as a supplier or intermediary

burden shifted to ARQ once taxpayer showed that it had business dealings with suppliers named in invoices

onus shifted to ARQ once the taxpayer had demonstrated that he had business deaings with issuer of mooted invoice