"I agree with Mr. Deyab that the Tax Court Judge erred in applying this Court’s decision in Lacroix to the facts of this case. It is evident from reading the Tax Court Judge’s reasons that he effectively addressed the issues of whether the Minister could reassess the statute-barred years and whether gross negligence penalties could be assessed collectively. He concluded, as noted in the excerpt from the oral reasons quoted at paragraph 16 above, that “the Minister has satisfied her onus under both subsections 152(4) and 163(2) of the Act”."