Wong v. The Queen, 2011 DTC 1079, 2011 TCC 30 (Informal Procedure) -- summary under Subsection 163(2)

Payments received by the taxpayer from a corporation of which he was a shareholder and over which he had operational control clearly were payments for services rendered rather than loan repayments (and, in fact, were called "salary" by the taxpayer in giving his evidence.) In these circumstances and given that the taxpayer was a capable and educated professional with work-related experience, the "high degree of blameworthiness involving reckless conduct" (para. 33) sufficient to establish the applicability of the gross negligence penalty had been made out by the Minister.