Special Risks Holdings Inc. v. Her Majesty the Queen and the Minister of National Revenue, [1995] 1 CTC 202, 95 DTC 5414 -- text
Isaac C.J.:-We are all of the view that there was evidence to support the finding of the learned trial judge that the appellant did not make a reasonable attempt to correctly determine its capital surplus on hand as required by subsection 184(3.1) of