Appellants: Jeremy Freedman and Joanne Lauria appealed Tax Court of Canada judgments rendered on October 13, 2021, in cases related to their 2006 income tax returns.

Central Issue: The main contention was whether the Minister of National Revenue had the authority to reassess the appellants outside of the normal reassessment period under subparagraph 152(4)(a)(i) of the Income Tax Act.

Tax Court's Decision: The Tax Court found that the Minister had the authority to reassess the appellants beyond the normal reassessment period.

Appeal's Basis: The appellants challenged the Tax Court's findings, arguing for an error in the judgment.

Federal Court of Appeal's Ruling:

• Agreed with the Tax Court's two-step approach and conclusions.
• Found that proceeds from share dispositions had been misrepresented on the appellants' 2006 tax returns.
• Concluded that these misrepresentations were due to carelessness or neglect, qualifying for reassessment under the Income Tax Act.

Appellants' Request: They asked the court to reweigh evidence and substitute its views for those of the Tax Court Judge, which was outside the court's role.

Outcome: The Federal Court of Appeal dismissed the appeals with costs, upholding the Tax Court's decisions and methodology.