What is the burden of proof for a Minister to make a reassessment outside of the normal reassessment period?

With respect to the Minister's burden of proof for making a reassessment outside of the normal reassessment period, Justice Strayer stated the following in the second paragraph of his conclusions in Venne v. Canada, [1984] F.C.J. No. 314 (F.C.T.D.): I am satisfied that it is sufficient for the Minister, in order to invoke the power under sub-paragraph 152(4)(a)(i) of the Act to show that, with respect to any one or more aspects of his income tax return for a given year, a taxpayer has been negligent. Such negligence is established if it is shown that the taxpayer has not exercised reasonable care. This is surely what the words "misrepresentation that is attributable to neglects" must mean, particularly when combined with other grounds such as "carelessness" or "wilful default" which refer to a higher degree of negligence or to intentional misconduct. . . .