Yazdani v. The Queen, 2012 DTC 1303 [at at 3983], 2012 TCC 371 (Informal Procedure) -- summary under Subsection 152(4)

The taxpayer invested money with a rogue (operating a business under the name "Regions"), and ultimately recovered only $6950 of his $31,000 outlay. The Minister assessed him beyond the normal reassessment period for investment deductions relating to Regions. In discussions with CRA officials, the taxpayer stated that he could not recall making the investments. Furthermore, testimony from the taxpayer in his wife's Tax Court appeals proved that he knew that Regions had a cash flow problem, and he was unable to explain why, knowing that, he would continue to invest in Regions. Favreau J. found that the taxpayer had made misrepresentations attributable to neglect, and therefore upheld the Minister's out-of-limitations-period assessments.