Concept
Loan Reconciliation
Deyab v. Canada, 2020 FCA 222 / B. Adverse Inference
"With respect to the reconciliation that was prepared, the Tax Court Judge noted, at page 15 of the transcript of his oral reasons:\n\nWhile it purports to provide a detailed reconciliation of the corporation’s shareholder loan account, I note that it critically does not reflect the substantial withdrawals in excess of $2 million that are at issue in these appeals. As a result, it is my view that this document is unreliable, and I have placed little weight on it. As discussed further below, it is my view that this document also critically undermines the credibility of Mr. Deyab’s testimony and his assertions."
Related Ideas
- Statute-barred YearsDeyab v. Canada, 2020 FCA 222 · II. Decision of the Tax Court
- Loan RecordsDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof
- Tax LiabilityDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof
- Shareholder BenefitsDeyab v. Canada, 2020 FCA 222 · II. Decision of the Tax Court
- Source EvidenceDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof
- Corporate LossesDeyab v. Canada, 2020 FCA 222 · (4) Should the Assessment of the Gross Negligence Penalties be Confirmed?
- Appeal IssuesDeyab v. Canada, 2020 FCA 222 · III. Issues and Standard of Review
- Burden ProofDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof