What is the case law on net worth assessments for income under the Income Tax Code?

I find that this is a case in which the assessor was quite justified in taking the net worth approach to income. Indeed, when taxpayers do not keep proper records, auditors have no other choice but to apply the net worth method of assessing. As Bowman J. said in the case of A.A. Ramey v. Canada, which is reported at [1993] 2 C.T.C. 2119 at 2122: ... The net worth method of estimating income is an unsatisfactory and imprecise way of determining a taxpayer's income for the year. It is a blunt instrument of which the Minister must avail himself as a last resort. A net worth assessment involves a comparison of a taxpayer's net worth, i.e., the cost of his assets less his liabilities, at the beginning of a year, with his net worth at the end of the year. To the difference so determined there are added his expenditures in the year. The resulting figure is assumed to be his income unless the taxpayer establishes the contrary. Such assessments may be inaccurate within a range of indeterminate magnitude but unless they are shown to be wrong they stand. It is almost impossible to challenge such assessments piecemeal. The only truly effective way of disputing them is by means of a complete reconstruction of a taxpayer's income for a year. A taxpayer whose business records and method of reporting income are in such a state of disarray that a net worth assessment is required is frequently the author of his or her own misfortunes. ... It is certainly true of the present case that the Appellants find themselves in the unfortunate position of having to dispute net worth assessments for four years solely by reason of their failure to have available accurate records.