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Statute-barred Years

Statute-barred Years (Fuscalite · II. Decision of the Tax Court) — "The “statute-barred years” are those that were reassessed after the expiration of the norma…

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The record addresses statute-barred years and the adequacy of the shareholders’ loan-account reconciliation.
Statute-barred years are years reassessed after the normal reassessment period had expired.
The evidence before the Tax Court Judge included a reconciliation of M.D. Consulting’s shareholders’ loan account.
The reconciliation appears to have been prepared after Mr. Deyab was reassessed.
The reconciliation did not reflect the substantial withdrawals at issue in the appeals.
The omitted withdrawals exceeded $2 million.
Mr. Deyab does not dispute that the reconciliation omitted these amounts.

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Statute-barred Years

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"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."

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