Charles and Gail Burrell v. Her Majesty the Queen, [1994] 2 CTC 2338 -- text
Bell J.T.C.C.:—The appeals of the two appellants were heard together. The issue is whether a penalty levied under the provisions of subsection 163(2) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"),