Hafizy - Federal Court of Appeal observes that appellants must topple the tree rather than tearing off branches

In appeals of Tax Court decisions before the Federa Court of Appeal, the standard of review for conclusions of mixed fact and law is "palpable and overriding error" (see McGoldrick).  Gauthier JA has repeated an admonition of Stratas JA that:

When arguing palpable and overriding error, it is not enough to pull at leaves and branches and leave the tree standing.  The entire tree must fall.

Neal Armstrong.  Summary of Hafizy v. The Queen, 2014 FCA 109 under s. 180(3).