The Minister reassessed the appellant beyond the normal reassessment period for the 2009 to 2012 taxation years using the net worth method, adding unreported business income and assessing gross negligence penalties.
The appellant argued the discrepancy was due to loans and gifts from family and friends.
The Tax Court found the Minister met the burden to reassess beyond the normal period and to assess penalties, as the appellant made misrepresentations attributable to wilful default.
However, the Court allowed the appeal in part, referring the matter back to the Minister to adjust the net worth calculations for certain proven loans, deposits, and business expenses.
