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section 462.48(2)
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462.48(2) An application under subsection (1.1) shall be made ex parte in writing to a judge and be accompanied by an affidavit sworn on the information and belief of the Attorney General or a person specially designated by the Attorney General for that purpose deposing to the following matters, namely, (a) the offence or matter under investigation; (b) the person in relation to whom the information or documents referred to in paragraph (c) are required; (c) the type of information or book, record, writing, return or other document obtained by or on behalf of the Minister of National Revenue for the purposes of the Income Tax Act to which access is sought or that is proposed to be examined or communicated; and (d) the facts relied on to justify the belief, on reasonable grounds, that the person referred to in paragraph (b) has committed or benefited from the commission of any of the offences referred to in subsection (1.1) and that the information or documents referred to in paragraph (c) are likely to be of substantial value, whether alone or together with other material, to the investigation for the purposes of which the application is made.

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not-guilty-by-reason-of-tax-painOnce a file is reviewed, a strategy must be developed to maximize the chances of an acquittal. In this tax evasion case, a novel approach was used that helped spare the client jail - and from a false conviction.
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