Arpeg Holdings Ltd v. The Queen, 2007 DTC 131, 2006 TCC 593
The taxpayer was unsuccessful in a submission that a CRA auditor had tricked the vice president of the taxpayer to sign a waiver and that the doctrine non est factum applied to that signature. Wood J. had no hesitation in concluding that the auditor did not set out to intentionally mislead the vice president, and it defied common sense that the auditor would think that the vice president could be fooled as to the nature of the document.
|Locations of other summaries||Wordcount|
|Tax Topics - General Concepts - Agency||83|
|Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(ii)||83|