What is the net worth of an individual who is not carrying on a business?

Canada (Federal), Canada

The following excerpt is from Garage Gilles Gingras v. The Queen, 2010 TCC 343 (CanLII):

That case illustrates the fact that the net worth method is commonly used as a last resort whenever taxpayers refuse to cooperate and provide documentation justifying their expenses and income. Taxpayers then have the burden of disproving the Minister’s estimate, in particular by producing appropriate documentation to support their allegations. Thus, even individuals not carrying on a business must keep some accounting records. Landry v. The Queen 2009 TCC 399

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