“[4] In Aridi c. La Reine, 2013 CCI 74 (CanLII), … the TCC states at paragraph 34 that “negligence of an accountant is not the factor that allows one to by-pass the time limit under 152(4)a)(i) of the ITA. It is the negligence of the taxpayer at the time of filing that must be analyzed.
…
“[7] The respondent recognizes that the judge does not specify which facts were wrongly declared in the tax return, nor what the appellant knew or should have known on this subject at the moment of their declaration.” [My translation]
New trial ordered.