It’s not enough for CRA to show an increase in net worth, even a large one, to meet its burden for opening a statute barred tax year. If the taxpayer neglected to report the income innocently through ignorance, CRA may not be able to reassess, if the normal reassessment period has passed.
See Lenneville (2013 TCC, Tardif, J.) esp. at paras. 28, 38 and 41.