The appellant corporation appealed a reassessment made beyond the normal reassessment period, which added $920,700 in unreported dividends to its income.
The appellant argued that the omission was due to a software error and the inattention of its external accountant, and that it had exercised due diligence.
The Tax Court of Canada dismissed the appeal, finding that the external accountant was negligent in failing to verify the tax return and that this negligence was attributable to the appellant.
Furthermore, the appellant's officers failed to exercise due diligence by not reviewing the tax return before it was filed.
