Onus

Hickman Motors followed, but same result under Sarmadi

non-granular pleading of the Minister failed to shift the onus to the taxpayer

onus on taxpayer re assessment underlying a s 160 assessment of the taxpayer

assessments vacated for failure to assume the policiers' ACB

Tax Court could determine a taxable benefit percentage (different from that assumed by the Minister) based on all the evidence

onus of proof rested at all times with the taxpayer

no burden of displacing an assumption as to a factual matter which the taxpayer could not be reasonably expected to know

onus on Minister to establish that her refund of a s. 163.2 penalty did not relate to any particular taxation year

onus on CRA where it, rather than taxpayer, had access to the records underlying a reassessment

taxpayers had the burden of disproving the Minister’s assumptions about their gift tax shelter about which they knew virtually nothing