The corporate appellant appealed GST/HST reassessments made beyond the normal reassessment period and the imposition of gross negligence penalties.
The Tax Court found that the appellant's reliance on its accounting staff without any oversight constituted neglect or carelessness, justifying the late reassessments.
However, the Minister failed to establish that the appellant's conduct amounted to gross negligence.
The appeal was allowed in part to vacate the penalties, while the reassessments for additional net GST/HST payable were upheld.
