"In describing the adverse inferences made by the Tax Court Judge, Mr. Deyab, in paragraph 5 of his memorandum, states:\n\n[…] The Judge concluded that the amounts he received from MD were taxable. In so concluding, the Judge drew adverse inferences against Mr. Deyab for not providing the Court with a properly reconciled shareholder loan account and for not calling any of his tax professionals to the hearing.\n\nThe Tax Court Judge then noted that the various banking statements would be available to Mr. Deyab and his accountants but Mr. Deyab did not call his accountant or his bookkeeper as a witness. The Tax Court Judge also noted that during the period following the issuance of the letters from the CRA to Mr. Deyab proposing the adjustments to his income to the time of the hearing of the appeal before the Tax Court (almost 4.5 years) Mr. Deyab did not provide an accurate shareholders’ ledger account for M.D. Consulting. With respect to the adverse inference he stated, at page 16 of the transcript of his oral reasons:\n\nI have drawn an adverse inference from the absence of such available evidence which may have supported Mr. Deyab’s testimony and assertions. The absence, in particular, of a credible shareholder’s reconciliation, in the face of substantial available financial records, in my view, critically undermines the credibility of Mr. Deyab’s testimony and assertions."