Statute-barred Years

"The “statute-barred years” are those that were reassessed after the expiration of the normal reassessment period for such years.\n\nThe evidence that was before the Tax Court Judge included a reconciliation of the shareholders’ loan account for M.D. Consulting. It appears that this reconciliation was prepared after Mr. Deyab was reassessed. However, as noted by the Tax Court Judge, this reconciliation did not reflect the substantial withdrawals in excess of $2 million that are in issue in these appeals. Mr. Deyab does not dispute that this reconciliation does not reflect these amounts."