" Any assumption of fact that attributed income to a shareholder solely on the basis that the corporation earned that income would not meet the requirement set out at paragraph 29 of The Queen v Anchor Pointe Energy Ltd., 2007 FCA 188 (CanLII), 2007 FCA 188, 2007 DTC 5379:
' Fairness requires that the facts pleaded as assumptions be complete, precise, accurate and honestly and truthfully stated so that the taxpayer knows exactly the case and the burden that he or she has to meet: Canada v. Anchor Pointe Energy Ltd., supra, at paragraph 23;Holm et al. v. The Queen, supra; Canada v. Lowen [2004 DTC 6321] 2004 FCA 146 (CanLII),  4 F.C.R. 3, at paragraph 9, (F.C.A.);Grant v. The Queen et al., 2003 DTC 5160, at page 5163; First Fund Genesis Corporation v. Her Majesty the Queen, 90 DTC 6337, at page 6340; Shaughnessy v. Her Majesty the Queen, 2002 DTC 1272, at paragraph 13; Stephen v. Canada,  T.C.J. No. 250, at paragraph 6.'
" Following the reasons in Anchor Pointe, merely pleading an assumption of fact, as the Respondent did in 8(i) and (j), that assumes that the income went directly through the corporation to the shareholder would be neither sufficiently complete nor precise in establishing the case that the Appellant has to meet. Such assumptions would have to provide details as to when and how the shareholder received those funds and benefits from the company. Failing to do so, the burden of proof would shift to the Minister to demonstrate that, on a balance of probabilities, a taxpayer was in receipt of unreported income from the corporation."
See Elbadawi v. The Queen, 2014 TCC 259 (D. Campbell)