Schmidt v. The Queen, 2013 DTC 1063 [at at 337], 2013 TCC 11 -- summary under Subsection 163(2)

The Minister imputed additional income to the taxpayer based on deposits into his bank account that he had not included in his return, and on that basis reassessed the taxpayer beyond the normal limitations period and imposed penalties. Hogan J. accepted the taxpayer's explanation that the amounts represented loans from his brother, and the accommodation of deposits of cheques from his brother's business. Unlike in Lacroix, the explanation of a loan from a sibling was credible - the taxpayer's brother had a hold on his account and was unable to make immediate withdrawals, whereas the taxpayer could. The Minister's assumptions were thus demolished.