http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/67312/index.do 
Johnson v. The Queen (March 18, 2014 – 2014 TCC 84) involved a taxpayer who claimed charitable donations of almost 50% of his taxable income. The Minister reassessed and, in so doing, opened up the otherwise statute-barred 2002 and 2003 taxation years. The court dismissed the appeal out of hand:
[32] The Respondent also established that Ambrose Danso-Dapaah [the tax return preparer] was charged with fraud and he entered a guilty plea to selling false charitable donation receipts. Ambrose Danso-Dapaah was a director and officer of CFCD [the charity issuing receipts to the appellant]. There were three crucial pieces of evidence which connected the Appellant to Ambrose Danso-Dapaah’s fraud. The first was that his 2002 and 2003 income tax returns were e-filed by Ambrose Danso-Dapaah. The second piece of evidence was a receipt for $1,550 for the Appellant’s 2003 year which was found on Ambrose Danso-Dapaah’s computer. The amount of this receipt equalled 10% of the Appellant’s alleged donation which was the amount Ambrose Danso-Dapaah charged his clients for the false charitable donation receipts. The third were the charitable donation receipts themselves. Ambrose Danso-Dapaah, as director and officer of CFCD, had access to these receipts.
[33] It is my opinion that the Respondent has met the onus given in subparagraph 152(4)(a)(i).
[34] It is my view that the Appellant did not make any donations to a charity in 2002 and 2003 and he and the person filing his tax returns for those years made misrepresentations that were attributable to fraud. The Minister was justified in reassessing the Appellant beyond the limitation period.
[35] The appeal is dismissed.