The appellant appealed reassessments for the 2010 to 2014 taxation years, which were issued beyond the normal reassessment period using the net worth method and included gross negligence penalties.
The Tax Court of Canada dismissed the appeal for 2012, allowed the appeal for 2013 and vacated the reassessment, and allowed the appeals for 2010, 2011, and 2014 to vacate the penalties and reduce the unreported income for 2014.
The Court found the appellant made misrepresentations attributable to neglect or carelessness, justifying the reopening of the statute-barred years, but gross negligence was only established for the 2012 taxation year.
