{"id":"W4416887628","doi":"10.2139/ssrn.5842002","title":"Unproven Allegations of Dishonesty, Wilful Blindness, or Gross Negligence: The Case for Cost Consequences in the Tax Court of Canada","year":2025,"lang":"en","type":"preprint","venue":"SSRN Electronic Journal","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":false,"ca_institutions":"","funders":"","keywords":"Taxpayer; Excise; Supreme court; Revenue; Liability; Summary judgment; Income tax; Payment; Tax court","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":false,"about_ca":true,"invisible_to_affiliation_only":true},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.002194901,0.0002161431,0.0003478408,0.0001651722,0.0003787095,0.0002276899,0.0008746011,0.0001098672,0.0000385998],"category_scores_gemma":[0.0005738891,0.0001231588,0.0001331826,0.0004606226,0.0001945658,0.0002559001,0.0001560215,0.001417617,5.33924e-7],"about_ca_system_candidate":true,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0003030417,"about_ca_system_score_gemma":0.009373856,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.630325,"about_ca_topic_score_gemma":0.9723288,"domain_scores_codex":[0.9978883,0.00006923649,0.0006638892,0.0002077581,0.0003524537,0.0008183469],"domain_scores_gemma":[0.9976977,0.0003374381,0.001178148,0.0002952015,0.0004812058,0.00001038053],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"theoretical_or_conceptual","study_design_scores_codex":[0.0005249621,0.0003963382,0.007134915,0.00116948,0.0006595639,0.0002038193,0.001676568,0.007451146,0.00003973969,0.9484069,0.01982189,0.0125147],"study_design_scores_gemma":[0.003022152,0.0001526384,0.001902418,0.001410826,0.0009588645,0.001149327,0.1471889,0.007312873,0.0001984846,0.5770875,0.2585008,0.001115206],"study_design_candidate":"theoretical_or_conceptual","study_design_consensus":"theoretical_or_conceptual","genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.8512859,0.009838035,0.009118194,0.1051527,0.004510172,0.008030205,0.0007808435,0.00005676595,0.01122726],"genre_scores_gemma":[0.9967199,0.0005022831,0.00002434077,0.0005554197,0.0005032797,0.0001061314,0.00003774196,0.00001186593,0.001539065],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.3713194,"threshold_uncertainty_score":0.996242,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.02387209583550803,"score_gpt":0.2847174287187368,"score_spread":0.2608453328832288,"validation_status":"score_only:v0-immature-baseline","note":"Baseline scores from an immature model (maturity gate not passed). Scores rank; they never assert a category."}}