The Minister reassessed the appellants, a wholesale poultry business and its owner, outside the normal reassessment period to include over $20 million in cash deliveries in their income and imposed gross negligence penalties.
The cash was delivered by a security company to the appellants' business address but was addressed to and collected by a third party.
The Tax Court of Canada allowed the appeals, finding that the Minister failed to prove on a balance of probabilities that the cash belonged to the appellants or was used for their benefit.
The assessments were vacated.
