http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/71344/index.do 
Elmansour et al. v. The Queen (April 25, 2014 – 2014 TCC 123) was an appeal by husband and wife of net worth assessments for 2002 to 2005 (husband) and 2002 to 2007 (wife). Neither had reported any income during the years in question.
The court first concluded that the Minister had established sufficient grounds to open statute-barred years of the husband but had not adduced sufficient evidence to open up the 2002 and 2003 taxation years of the wife.
Mr. Elmansour did not object to the net worth computation other than the opening cash on hand. He argued, and the court accepted, that the computation should take into account his foreign investments at the beginning of the period:
[59] The amount of 597,281 dirhams (CAN $256,233) was in different accounts that Mr. Elmansour had at the National Bank of Abu Dhabi. One account was in US dollars, another account was in sterling and still another was in dirhams. In 2003, he transferred the funds in those three accounts to another account that he already had at the National Bank of Abu Dhabi. He withdrew from the latter account 597,281 dirhams (CAN $256,233) and had that amount transferred to Canada. He used the money as a down payment on the house that he bought in Ajax.
[60] Counsel for the respondent brought to my attention evidence that showed that on October 6, 2002, Mr. Elmansour had in his dirhams account 237,235 dirhams. By October 14, 2002, he had 367,784 dirhams in the account, an increase of 130,548 dirhams (CAN $55,900). Counsel for the respondent wondered about the source of the 130,548 dirhams. In other words, where did the 130,540 dirhams come from?
[61] Mr. Elmansour stated that the 130,548 dirhams was a loan that he obtained from the National Bank of Abu Dhabi. He did not file any documents proving that it was a loan.
The court did not however accept his evidence that the 130,548 dirhams was a bank loan. The court similarly rejected his evidence that he had brought $250,000 with him when he and his family moved to Canada. Thus his appeal was allowed in part, with costs to the respondent.
In the case of Mrs. Elmansour the court rejected her evidence of an inheritance of $80,000 from her mother and gifts from her brother:
[75] During the hearing, Ms. Elmansour’s testimony was vague and self‑serving. I cannot, in the absence of corroborative or probative evidence in the form of reliable documentation or credible testimony, accept her testimony that her brother gave her cash gifts.
[76] With respect to expenditures, the CRA auditor analyzed the statements for each of Ms. Elmansour’s bank accounts in order to determine what her expenditures were. The CRA auditor listed all the expenditures that he included in determining her net worth. She did not challenge any of these expenditures. The burden of proof was on her; she had to prove that the expenditure figures used were incorrect.
[77] Therefore, with respect to expenditures, no adjustments should be made to Ms. Elmansour’s net worth for the 2004, 2005, 2006 and 2007 taxation years.
Her appeal was also dismissed with costs to the respondent.