Hickman Motors Ltd. vs. Canada, 1997 CanLII 357 (SCC), [1997] 2 S.C.R. 336 at paragraphs 92 to 94; House v. Canada, 2011 FCA 234 (CanLII), 2011 FCA 234, 422 N.R. 144
Burden of Proof is not Static
“the taxpayer’s initial onus of “demolishing” the Minister’s exact assumptions is met where the appellant makes out at least prima facie case; where the Minister’s assumptions have been “demolished” by the appellant, “the onus … shifts to the Minister to rebut the pri...
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