"In determining that the Minister of National Revenue (Minister) could reassess the statute-barred years and also assess gross negligence penalties, the Tax Court Judge relied mainly on the decision of this Court in Lacroix v. Canada, 2008 FCA 241:\n\nIn my view, the test set out by the Federal Court of Appeal at paragraph 32 of Lacroix applies in this case. In this respect, the Minister has clearly established, and the Appellant has admitted, that Mr. Deyab received $2,349,779 from M. D. Consulting 2005 Inc., which he did not report in his income during the taxation years under appeal. In my view, as previously discussed, Mr. Deyab has not provided a credible explanation for the discrepancy between his reported income and those substantial amounts admittedly received by Mr. Deyab from M. D. Consulting 2005 Inc. As a result, it is my view that the Minister has satisfied her onus under both subsections 152(4) and 163(2) of the Act.\n\n[page 29 of the transcript of the Tax Court Judge’s oral reasons]"