The appellant appealed reassessments for the 1998 to 2015 taxation years, which included income from an undisclosed Swiss bank account and imposed gross negligence and failure to file penalties.
The Tax Court found the appellant made misrepresentations attributable to neglect or carelessness for 1998 to 2013, justifying reassessments beyond the normal period, and upheld the penalties for those years.
The appeals for 2014 and 2015 were allowed as the Minister provided no evidence to justify reassessing those statute-barred years.
