Middlebrook v. Canada, 2013 DTC 5001 [at at 5501], 2012 FCA 264 -- summary under Subparagraph 152(4)(a)(i)

The Court affirmed the trial judge's finding of fact that a number of the taxpayers' receipts for inventory were spurious - no inventory was delivered, or was ever meant to be, and funds for the ostensible inventory were rerouted back to the taxpayers. Among the reasons for affirming the judge's findings were that the witnesses gave vague testimony and the taxpayers failed to call witnesses that ought to have been able to support the taxpayers' claims. The misrepresentations also warranted reassessment beyond the limitations period.