"Subsequent to the hearing, the parties notified the Court that if Mr. Deyab was partially successful then the parties agreed that no costs should be awarded in either this Court or the Tax Court.\n\nAs a result, I would allow the appeal, without costs, with respect to the assessment of the gross negligence penalties but otherwise dismiss Mr. Deyab’s appeal. I would, therefore, set aside the Judgment issued by the Tax Court and render the following judgment (which reflects the amounts as agreed upon by the parties at the Tax Court hearing and the deletion of the gross negligence penalties):\n\nThe appeals from the reassessments made under the Act for Mr. Deyab’s 2007, 2008, 2009, 2010 and 2011 taxation years are allowed, without costs, and the reassessments are referred back to the Minister for reconsideration and reassessment on the basis that:\n\n(a)\n\nMr. Deyab’s 2007 taxable income be reduced by $82,501;\n\n(b)\n\nMr. Deyab’s 2008 taxable income be reduced by $113,200;\n\n(c)\n\nMr. Deyab’s 2009 taxable income be reduced by the amount of $115,858;\n\n(d)\n\nMr. Deyab’s 2010 taxable income be reduced by $167,035;\n\n(e)\n\nMr. Deyab’s 2011 taxable income be reduced by $11,308;\n\n(f)\n\nthe amount of applicable interest should be consequently reduced in respect to the foregoing paragraphs (a) to (e);\n\n(g)\n\nall of the penalties assessed under subsection 163(2) of the Act be deleted; and\n\n(h)\n\nMr. Deyab’s appeal is dismissed in all other respects."