The failure of the taxpayer to include in his income the reimbursement by a corporation of expenses incurred by him in connection with a criminal prosecution of him did not permit the Minister to assess the year in question beyond the statute-barring period, given that the correct treatment of such reimbursements was by no means clear. Tardif, J. also stated (at para. 59):
"I do not believe that evidence of a single error resulting from the presence of an inaccurate fact is sufficient to preclude the effect of the time limit in the Act. Rather, I think that there needs to be evidence of a more serious wrongdoing than mere error."