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Record W4385608461 · doi:10.54208/1000/0006/005

A Ride With My Best Friend: The Fiscal Arbitrators Pseudolaw Tax Evasion Scheme, Recruitment, and Litigation

2023· article· en· W4385608461 on OpenAlexaboutno aff
Donald Netolitzky

Bibliographic record

VenueInternational journal of coercion, abuse, and manipulation · 2023
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicCorporate Taxation and Avoidance
Canadian institutionsnot available
Fundersnot available
KeywordsAppealRevenueAgency (philosophy)PopulationIdeologyBusinessEconomicsLaw and economicsLawFinancePolitical scienceSociology

Abstract

fetched live from OpenAlex

Fiscal Arbitrators was a comparative short-lived Canadian pseudolaw tax avoidance scheme that operated between 2006-2012. Taxpayers made “Strawman Theory” claims to create large but fictitious business expenses. Taxpayers who employed Fiscal Arbitrators techniques had no legal basis for their claims. The Canada Revenue Agency assessed “gross negligence” penalties in addition to other automatic charges. At least 500 Fiscal Arbitrators customers appealed their taxation re-assessments at the Tax Court of Canada. There, these taxpayers usually claimed their actions, and blatantly false tax returns, had a reasonable basis. This unusual confluence of factors resulted in a substantial number of written court decisions that include first-hand, first-person, accounts of how and why Fiscal Arbitrators’ customers were recruited, and that describe this “Detax” scheme’s operation. Unexpectedly, Fiscal Arbitrators customers were primarily recruited via person-to person contacts and through family, social, and workplace networks. No Internet based recruitment was reported. Fiscal Arbitrators customers showed little to no interest in or understanding of the basis for their extraordinary claims. Their sole motivation was greed. These taxpayers were mainly non-ideological “mercenaries” who abandoned pseudolaw to conduct damage control steps as rational self interested actors. Most voluntarily terminated their appeals prior to a full appeal court hearing. The characteristics of this study’s Fiscal Arbitrators population do not correspond with how legal, media, and academic sources stereotypically portray and describe pseudolaw adherents. This investigation thus illustrates pseudolaw’s users are potentially more diverse than is commonly recognized.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

How this classification was reachedexpand

Full frame machine prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.

metaresearch head score (Codex)0.006
metaresearch head score (Gemma)0.019
Version: metacan-v3-hybrid-931329e0061cValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Qualitative · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: Empirical
Teacher disagreement score0.432
Threshold uncertainty score0.858

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0060.019
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0010.001
Science and technology studies0.0150.005
Scholarly communication0.0060.002
Open science0.0010.002
Research integrity0.0020.002
Insufficient payload (model declined to judge)0.0080.001

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.051
GPT teacher head0.273
Teacher spread0.223 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.

The models applied no category: nothing in the taxonomy fit this work.
Study designQualitative
Domainnot available
GenreEmpirical

How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".

Quick stats

Citations0
Published2023
Admission routes1
Has abstractyes

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