Watson
D.J.T.C.
(orally):
His
Honour:
As
I
said
earlier
and
as
counsel
pointed
out,
it
is
difficult,
when
a
person
has
a
substantive
appeal
on
a
subject
matter,
to
dismiss
it
on
technical
grounds
but
the
law
is
very
clear
and
I
do
not
have
any
discretion
in
this
matter.
I
have
to
apply
the
law
as
it
is
written.
As
I
said
earlier,
everyone
is
presumed
to
know
the
contents
of
the
Income
Tax
Act.
That
is
why
tax
lawyers
and
accountants
and
chartered
accountants
make
a
living
doing
this
stuff,
because
most
people
in
Canada
I
suppose
don’t
understand.
But
it
is
clear
that
because
a
person
does
not
understand
the
contents
of
the
Income
Tax
Act,
it
does
not
forgive
it.
It
doesn’t
excuse.
The
law
still
has
to
be
applied.
And,
in
these
cases
here,
it
is
always
difficult
for
the
Court
because
often
we
can
feel,
and
I
am
sure
counsel
for
the
Minister
feels
the
same
way,
that
in
many
walks
of
life
and
many
things
in
life,
we
do
things
because
we
were
not
fully
informed
and
we
didn’t
know.
We
might
have
done
it
some
other
way
if
we
had
known.
We
say,
“Well,
I
didn’t
know.
But
the
gun
was
loaded.”
Unfortunately
we
have
to
apply
the
law.
I
am
satisfied
that
on
the
basis
of
the
testimony
we
have
had
this
morning
and
the
documentary
evidence,
that
the
application
should
be
dismissed.
So
it
is
accordingly
dismissed.
MR.
WINSOR:
Thank
you
Your
Honour.
HIS
HONOUR:
Thank
you
very
much
for
coming
this
morning
and
it
is
worthwhile
coming.
You
don’t
want
to
just
let
it
go
by
default.
So
I
think
it
is
important
for
you
to
come
this
morning
and
thank
you
for
coming.
MR.
WINSOR:
Thank
you
for
your
interest
Your
Honour.
I
appreciate
it.
Application
dismissed.
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