"During the years 2007 to 2011, various amounts were withdrawn from the account of M.D. Consulting and transferred to Mr. Deyab’s personal account or the accounts of his immediate family members, and M.D. Consulting paid certain personal expenses. Mr. Deyab was reassessed to include the following amounts in his income:\n\nTaxation Year\n\nAmount Included in Income\n\n2007\n\n$103,837\n\n2008\n\n$232,212\n\n2009\n\n$212,867\n\n2010\n\n$2,199,746\n\n2011\n\n$115,547\n\nMr. Deyab was reassessed on the basis that these amounts were benefits that were conferred on him as a shareholder of M.D. Consulting and hence were included in his income under subsection 15(1) of the Act.\n\nFor the years 2007 to 2010, the notices of reassessment were issued after the expiration of the normal reassessment period. As well, for each taxation year, gross negligence penalties were assessed under subsection 163(2) of the Act."