BUSINESS INCOME
What can you do if CRA’s disallows or reduces an expense that you claimed?
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If you commence a court action to appeal the CRA’s assessment, each of the CRA’s factual assumptions will be presumed true by the court unless you present evidence to rebut them. At the end of the day, a judge will make a decision taking into account all the evidence presented, and it will decide facts based on a balance of probabilities, which requires the court to determine whether it is more likely than not that a fact happened or an event occurred.[1]
[1] See Hickman Motors Ltd. v. Canada (1997 SCC), Yogeswaren v. HMQ (2021 Tax Court) paragraph 6; Eisbrenner v. Canada (2020 FCA)