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Citation: 2005TCC187
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Date: 20050318
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Docket: 2004-1902(IT)I
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BETWEEN:
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ALAIN MORRISSETTE,
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Appellant,
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and
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HER MAJESTY THE QUEEN,
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Respondent.
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[OFFICIAL ENGLISH TRANSLATION]
REASONS FOR JUDGMENT
Tardif J.
[1] This is an appeal from assessments made using the net worth method and concerning the 1995, 1996, 1997, 1998 and 1999 taxation years. This appeal also pertains to penalties imposed on the Appellant, first for late filing, and second for wilful omissions under subsection 163(2) of the Income Tax Act ("the Act").
[2] The Minister of National Revenue (the "Minister") relied on the following assumptions of fact as the basis and justification for the assessments under appeal:
[TRANSLATION]
22. (a) During the years in issue, the Appellant operated an auto sales and repair business.
(b) Upon filing his income tax returns, the Appellant declared net business income of $8,120 for the 1996 taxation year, $6,951 for the 1997 taxation year, $4,094 for the 1998 taxation year and $8,309 for the 1999 taxation year.
(c) The Appellant's income tax returns for the taxation years in issue were audited by the Minister of National Revenue.
(d) Since the business operated by the Appellant lacked any internal controls, the Minister used the net worth method to arrive at the reassessments of December 23, 2002.
(e) The auditor's summary of adjustments and determination of additional income for the notices of reassessment of December 23, 2002, are attached to this Reply as Appendix A, which is an integral part hereof.
(f) The auditor essentially established the Appellant's family's cost of living based on figures from Statistics Canada.
(g) The Appellant claims to have borrowed $10,000 from his mother Louise Lefebvre during the 1998 taxation year.
(h) After examining the Appellant's bank account and Ms. Lefebvre's, the Minister determined that she never lent him any money.
(i) The auditor took account of the fact that the Appellant lived alone with his spouse during the 1995 and 1996 taxation years, and that he lived with his spouse and her son during the 1997, 1998 and 1999 taxation years.
23. After the Appellant objected to the reassessments of December 23, 2002, which pertained to the 1995, 1996, 1997, 1998 and 1999 taxation years, the Minister of National Revenue made the following adjustments:
(a) The Minister issued a reassessment for the 1995 taxation year cancelling the undeclared income and the related penalty.
(b) The amount of $2,500 under "other assets" for the 1996, 1997, 1998 and 1999 taxation years was cancelled.
(c) The amounts allocated by the audit to dental care, insurance, haircuts, toys, computer games and newspapers (except for 1999) were cancelled.
(d) The cost-of-living expenses established by the audit based on Statistics Canada figures were revised downward as follows in accordance with the Appellant's representations:
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1996
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1997
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1998
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1999
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Cost of living according to audit
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$33,953
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$34,026
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$32,525
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$32,469
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Cost of living following objection
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$20,836
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$24,093
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$24,339
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$25,513
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(e) The summary of the revision of each of the Appellant's cost-of-living elements following the objection is attached to this Reply as Appendix B and is an integral part hereof.
(f) The value of each asset and liability was established based on documents or information supplied by the Appellant.
(g) By taking account of the Appellant's non-taxable capital gain, the Minister reduced by $3,117 the difference that the auditor had obtained in respect of the 1995 taxation year.
(h) The Minister added the property taxes on the Appellant's residence to his cost of living, and reduced his liabilities for the years in which those taxes remained unpaid.
(i) The Appellant filed his income tax return with the Minister for the 1995 taxation year on January 22, 1997.
(j) The summary of readjustments and determination of additional income following the objection is attached to this Reply as Appendix C and is an integral part hereof.
[Emphasis in the original.]
[3] The Appellant admitted to the facts set out in paragraphs 22 (b), (c), (f) and (g) and in paragraphs 23(a), (b), (c), (g) and (i).
[4] The Appellant filed an amended Notice of Appeal with the Respondent's consent. The new facts alleged in the amendment are limited in scope to paragraph 23, which, as amended, reads as follows:
[TRANSLATION]
23. In addition, the Appellant did not deduct capital cost allowance amounts for the taxation years 1996 through 1999. Those amounts are $6,400 for 1996, $11,839 for 1997, $5,950 for 1998 and $7,238 for 1999.
[Emphasis in the original.]
[5] At the outset, counsel for the Appellant stated that the evidence he intended to adduce would address only the following three elements.
· The Appellant got a $10,000 loan from his mother Louise Lefebvre.
· The Appellant made no vacation-related expenditures during the taxation years.
· The Appellant should have had the benefit of the provisions concerning capital cost allowance.
[6] With regard to the $10,000, the Appellant's mother explained that she advanced $10,000 to her son, specifically $3,000 for the 1997 taxation year and $7,000 for the 1998 taxation year.
[7] She said that she operated a restaurant that was not doing well in 1997. In addition to the financial problems that she was having with her own restaurant's operations, her son, the Appellant, allegedly insisted that she help him financially. In order to meet her financial needs and her son's, she allegedly obtained a $10,000 loan from her aunt Louise Lefebvre (Exhibit A-27).
[8] First, she deposited the $10,000 into the restaurant's operating account. Then, she lent $3,000 to her son, the Appellant, in two instalments of $1,500 each during the 1997 taxation year. In the following year, 1998, she allegedly made three payments to her son totalling $7,000. This adds up to $10,000 for the two taxation years.
[9] The amounts lent to the Appellant were allegedly taken from her restaurant's operating account and paid to her son in cash. The son's testimony mirrored his mother's explanations.
[10] The Appellant stated that the cash was used to purchase one or more "beaters" (used cars of little value) which he was unable to describe. The money was never deposited into a bank account.
[11] The Appellant signed no acknowledgement of debt, and the financial statements of his business, which profited from the money, make no reference to the Appellant's debt to his mother.
[12] The explanations that were provided did not establish that the son had any urgent need at all. Quite the opposite is true: according to the Appellant's own testimony, the money was needed so that he could purchase vehicles to add to his inventory.
[13] This explanation is so totally unreasonable that it is simply not plausible. How can one find a modicum of plausibility or rationality in an explanation to the effect that the Appellant obtained the money from his mother, who had no money, and would have needed to borrow it at a time when her own situation was precarious by her own admission?
[14] If this is what happened, she would not have benefited in any way from the borrowed funds, which would have served to increase her son's business inventory at a time when she seriously and urgently needed funds. In my view, this story is a complete fabrication.
[15] The fact that all five transactions were done in cash, and that there were no deposits, or references to the transactions in the Appellant's financial statements, further weakens the explanation. Lastly, the Appellant never signed an acknowledgment of debt or a note to his mother, and, as I mentioned, she did not have the wherewithal to advance the funds; quite the contrary, her restaurant, which was her livelihood, was not doing well financially.
[16] It appears that the Appellant did not give his mother an acknowledgment of his debt. There is nothing illegal or abnormal about making various loans in cash. However, the absence of entries in the books of the Appellant's business, the lack of an acknowledgment of debt, and the overall context, including his mother's difficult financial situation, make the entire story of the $10,000 advance implausible, especially since the efforts to obtain the money would largely have stemmed from the financial needs of the Appellant's mother in connection with her restaurant, and since she would not ultimately have derived any benefit from what she borrowed.
[17] The Appellant's second argument is that he spent nothing on vacations. While the amounts allocated are low, the only basis for their allocation is the statistical data that the Canada Customs and Revenue Agency often refers to when making assessments using the net worth method. Thus, those additions are essentially arbitrary. The Appellant categorically denied spending anything at all on vacations.
[18] Whatever doubts I might have regarding the plausibility of this denial, I will accept the explanation because there is no justification for imputing the expenses. These are not essential expenses like food and lodging, in respect of which clearer evidence would have been needed for the Court to find that they were not incurred.
[19] The final component of the dispute pertains to capital cost allowance. This question of a capital cost allowance for certain assets accounted for most of the time that both parties devoted to their evidence.
[20] The Appellant immediately objected to the Respondent revising certain figures. He argued that they constituted new facts which placed him in a difficult position in that he was no longer able to provide adequate evidence.
[21] The Respondent replied that evidence of certain corrections needed to be adduced, and that the primary reason for this need was the fact that an amended Notice of Appeal has been filed raising new facts such as the following:
[TRANSLATION]
23. In addition, the Respondent did not deduct capital cost allowance amounts for the taxation years 1996 through 1999, which totalled $6,400 for the 1996, $11,389 for 1997, $5,950 for 1998 and $7,238 for 1999.
[Emphasis in the original.]
[22] As stated, the Appellant, with the Respondent's consent, filed an amended Notice of Appeal. By reason of this amendment, the issue of capital cost allowance became an important aspect of the appeal. Consequently, the Court was stunned that the Appellant was taken by surprise and unable to offer adequate evidence. After all, the facts originated with him.
[23] It was in this context that, at the hearing of October 4, 2004, the Respondent adduced evidence contradicting the Appellant's new position regarding the capital cost allowance, subject to the Court's decision on the merits of the objection, which was taken under advisement.
[24] I dismiss the Appellant's objection. The Respondent may indeed present evidence in reply to the elements submitted by the Appellant. Subsection 152(3) of the Act expressly provides for this situation:
Alternative basis for assessment
152. (9) The Minister may advance an alternative argument in support of an assessment at any time after the normal reassessment period unless, on an appeal under this Act
(a) there is relevant evidence that the taxpayer is no longer able to adduce without the leave of the court; and
(b) it is not appropriate in the circumstances for the court to order that the evidence be adduced.
[25] In the case at bar, the Respondent is merely replying to an argument raised by the Appellant. The Appellant cannot suffer prejudice by reason of evidence presented by the Respondent in response to an argument that he is raising himself. On the contrary, there would be considerable prejudice to the Respondent if she were refused the right to respond to a new argument raised by the Appellant.
[26] In The Queen v. Loewen, [2004] 4 F.C.R. 3, the Federal Court of Appeal had the occasion to consider subsection 152(9) of the Act:
11 The constraints on the Minister that apply to the pleading of assumptions do not preclude the Crown from asserting, elsewhere in the reply, factual allegations and legal arguments that are not consistent with the basis of the assessment. If the Crown alleges a fact that is not among the facts assumed by the Minister, the onus of proof lies with the Crown. This is well explained in Schultz v. Canada, [1996] 1 F.C. 423 (C.A.) leave to appeal to S.C.C. refused, [1996] S.C.C.A. No. 4.
. . .
13 There is another line of jurisprudence that establishes the principles upon which the Crown may be permitted to defend an assessment by relying on a legal argument that was not part of the basis of the assessment. Generally, such new legal arguments are permitted if they arise from the evidence presented in the Tax Court proceedings. The scope of the evidence presented in the Tax Court is itself limited by the pleadings. The result is that new legal arguments are permissible to the extent that they are consequential on the facts alleged in the pleadings, including the notice of appeal, the assumptions in the reply, and any additional facts alleged in the reply.
. . .
21 As I read subsection 152(9), the expiration of the normal reassessment period does not preclude the Crown from defending an assessment on any ground, subject only to paragraphs 152(9)(a) and (b). Paragraphs 152(9)(a) and (b) speak to the prejudice to the taxpayer that may arise if the Crown is permitted to make new factual allegations many years after the event.
[27] Thus, the Respondent was entitled to present new evidence and new arguments in support of her reassessment provided they do not have the effect of increasing the amount of the assessment under appeal. The Federal Court of Appeal permitted this approach in The Queen v. Anchor Pointe, [2002] T.C.J. No. 502 (QL):
40 Here, the Minister does not seek to rely on Global to increase Anchor Pointe's taxes payable over what was included in the Minister's reassessment prior to expiry of the normal reassessment period. The reassessment increased taxes payable by reducing CEE deductions by the difference between the amount claimed and the amount based on the Minister's estimation of the fair market value of the seismic data. On confirming the reassessment, the Minister does not seek to increase that amount. He is not introducing a new transaction. He is only relying on an additional argument, that there is no CEE deduction allowed where the acquisition of the seismic data is for resale or licensing.
41 In these circumstances, I agree with Rip J.'s conclusion that there is nothing objectionable about the Crown's Reply containing an additional argument based on the Global decision.
[28] The Appellant submits that the calculation of net worth should have included an adjustment to take account of the capital cost allowance claimed by the Appellant for each of the years in issue.
[29] However, it appears from the statement of net worth that the items of property in respect of which a capital cost allowance was claimed were not included when the change of net worth was calculated.
[30] The statement that the Appellant submitted to the Canada Customs and Revenue Agency for the 1995 taxation year states that he does not have the property for which he wishes to deduct a capital cost allowance.
[31] The financial statements submitted for 1996 do refer to such property at year-end.
[32] While the Appellant maintains that he had this property prior to the 1996 taxation year, the evidence adduced is not very persuasive, especially since the first financial statements for the 1996 taxation year stated that it was the first year of the business (Exhibit A-17). The financial statements contain two columns: one entitled "1996" and another entitled "opening," which has corresponding numbers instead of referring to the previous taxation year.
[33] In addition, the time that the property in question was acquired remains unclear. When was it acquired? What was it worth in 1996? These are two important questions. Despite their pertinence, no valid and credible explanation was given. The evidence on this question boils down to the following questions and answers (transcript, at pages 126-8):
[TRANSLATION]
. . .
Q. O.K. The office furniture . . . did you buy it in '96?
A. No.
Q. Where does that office furniture come from?
A. Well, it's what I had purchased for my other business.
Q. The business you are talking about is?
A. The high-pressure cleaning and wet blasting business.
Q. O.K. Good. So the document tendered earlier shows this property . . . this is . . . the document tendered as Exhibit I-5.
CLERK: Financial statements at December 31, '99.
ALAIN BOLDUC:
Q. Excuse me! That's not it. Exhibit I-4. Those items of property are not listed in the statement that was made. Do you know why they're not on it?
A. No idea. I know that I looked, I know that all my personal property is there. But there's nothing there that's related to my business.
Q. So, none of the property you just mentioned is on it?
A. No.
Q. And you don't know why?
A. No idea.
Q. Your witness.
. . .
[34] Counsel for the Appellant aptly summarized the question of capital cost allowance at paragraphs 19 et seq. of his written argument:
[TRANSLATION]
19. For the purposes of this new net worth calculation, we added $49,000 to the item "business equipment" for 1994 and 1995 because the Appellant said at the hearing that, with the exception of the hauler purchased for $10,000 in 1996, he has owned all the property listed in the 1996 financial statement (tab 17) for several years.
20. Thus, in the 1996 statement, we entered $59,000 under "business equipment" to take account of the purchase of the hauler valued at $10,000. In addition, we added the item "business hauler loan" for the year 1996 because the Appellant said during the hearing that the hauler was financed at $10,000 upon purchase.
21. We entered $59,194 under the item "business equipment" for the 1997 year because office furniture went from $9,000 to $9,194 on the 1997 financial statement (tab 19).
22. For 1998, we entered $49,352 under "business equipment" because the Appellant said he disposed of the hauler, and because, in the 1998 financial statement (tab 21), the amount is $9,352 instead of $9,194. We also entered $5,000 for "business hauler loan" because the Appellant said he was making payments to the vendor and because the debt was repaid in full at the time of disposition in 1998.
23. With respect to the 1999 year, we entered an amount of $50,502 under "business equipment" because the amount in the 1999 financial statement (tab 23) under "cleaning equipment" is $16,150 instead of $15,000.
24. We remind you that, although the hauler is listed on the 1998 and 1999 financial statements, counsel for the Respondent admitted, following the Appellant's testimony that he disposed of the hauler in 1998, that the hauler should no longer appear on the 1998 and 1999 financial statements, and this enabled us to avoid calling the Appellant's accountant as a witness. In fact, the value in those financial statements was restated as $0 to take account of the disposition.
25. The new calculation results in a positive difference of $226 for 1996, a negative difference of $3,928 for 1997, a negative difference of $1,149 for 1998 and a positive difference of $10,741 for 1999.
26. In this regard, we submit that the notices of reassessment respecting the 1996, 1997 and 1998 years should be set aside, and that they should be amended to reflect $10,741 in undeclared income in the year 1999.
27. Lastly, while the Respondent attempted to prove to the Court that the Appellant purchased $59,000 worth of equipment for his business in 1996 (net worth Exhibit I-1) which would bring his undeclared income to $59,539.96 for that year, we submit to you that this is completely impossible because, based on the evidence, the Appellant had financial problems that required him to borrow money from his mother, and was very often late in paying his municipal taxes based on the documents tendered as Exhibit A-29.
[35] The fundamental question that arises from the Appellant's comments is whether the Court accepts his explanation regarding the value of the "business equipment" and the time that it was purchased.
[36] In view of the significance of the amounts in issue - but especially given the impact on this case - the evidence would have needed to be more substantiated and persuasive than a mere assertion that the Appellant had been in possession of the business equipment for several years.
[37] The value of this equipment has not been established. Moreover, much of the property has a very high rate of depreciation or a very short useful lifespan. The computer system is just one example of this. Such systems become obsolete very quickly.
[38] Despite this reality, the Appellant essentially stated that he had owned the property for several years and could not have afforded to purchase it during the period in issue in any event. No objective fact, and no document or other testimony was adduced to support or confirm the Appellant's mere assertion.
[39] However, the financial statements concerning the commencement of the business' operations, which the Appellant himself tendered at the beginning of the hearing, make no reference to such property. The Appellant claims not to know the reason for this silence or absence, except perhaps a mistake.
[40] This is where the Appellant's argument that he could never have afforded to buy such property for himself turns against him. How can a person of such little means fail to notice the absence of such significant property from his balance sheet?
[41] The unconfirmed oral explanation totally contradicts a written document whose reliability must be presumed and taken as fact absent decisive and reliable evidence to the contrary. I do not accept the Appellant's explanations regarding the "business equipment," so there is no reason to consider the Appellant's arguments regarding the capital cost allowance that he wanted to claim on certain property whose ownership was not established in a manner satisfactory to the Court.
[42] For the above reasons, the Court does not accept the Appellant's claims regarding the "business equipment." However, I acknowledge the admission regarding the tow truck purchased for $10,000 and financed entirely by the vendor, all of which has no effect on the 1998 and 1999 taxation years.
[43] The admission was worded as follows (transcript, at pages 123-25 and 128-29):
[TRANSLATION]
. . .
Q. A hauler you acquired . . . you did indeed acquire a hauler in '96 . . .
A. Yes.
Q. . . . for Action Remorquage 04?
A. Yes.
Q. Alright. Could you say who you bought that hauler from?
A. Yes, from Marc Laroche pièces d'autos.
Q. O.K.
THE COURT:
Q. In Victoriaville?
A. No, in Pointe-du-Lac.
ALAIN BOLDUC:
Q. You paid $10,000 for it, as shown in the financial statements?
A. Yes.
THE COURT: Just a second.
Q. Let's agree on what's involved. The word "hauler" could mean several things to an average person like me. It could mean a trailer . . .
A. No, Your Honour, it's a tow truck.
Q. . . . and it can mean a "tow truck" as well.
A. It's a tow truck.
Q. It's a tow truck. O.K.
ALAIN BOLDUC:
Q. This is something that I also wanted to ask in order to clarify matters. Perfect. Alright. You bought it in '96. Do you remember how you paid for it? Was there . . . did you pay $10,000 for it, in all? Did you have terms of payment? How did it happen?
A. It was financed for me by Marc Laroche pièces d'autos.
Q. O.K. When you made the purchase, the debt, I mean, from '96, do you remember the amount that was financed?
A. $10,000.
Q. All of it was financed?
A. Yes. Yes, yes, at the beginning, yes. I gave money afterwards. But at the beginning, all of it was financed.
Q. Alright. Later, you also had in the financial statements for . . . O.K. Later, in '98, if we look at page 7 of the '98 financial statement, it says [TRANSLATION] "Hauler: $10,000, net value: zero." What happened to that tow truck in '98?
A. In '98 I brought it back. I sold it back to Marc Laroche pièces d'autos, I exchanged it because I had finished paying for it, in '98 if I'm not mistaken, and I exchanged it for two vehicles . . . two cars.
Q. O.K. So that was '98. And in '99, did you buy other haulers . . . other tow trucks?
A. No.
. . .
CROSS-EXAMINED BYANNICK PROVENCHER:
Q. I have just one question. You claim that when you disposed of your hauler in '98, you received two vehicles in exchange. Which vehicles were those?
A. I don't exactly remember the kind, but I could have the papers taken out.
Q. No, but as far as you can recall, what did you do with those vehicles?
A. Oh! I resold them.
Q. O.K. I have no further questions.
. . .
ANNICK PROVENCHER: Alright. In light of what has just been heard, I think he was the best witness to testify about the property that he had in '98. And I am happy that he came to testify, and we are satisfied with regard to the issue of capital cost allowance in '98, that it was validly declared in his tax return. He did indeed dispose of it, and there are two cars in exchange. I don't think we need to hear Ms. Cyr tomorrow morning.
. . .
[44] The evidence regarding the issue of capital cost allowance was primarily concerned with a tow truck purchased for $10,000, but the amount was entirely financed by the vendor.
[45] The Respondent accepted the Appellant's explanations regarding the tow truck in question. The Appellant explained that it was a used tow truck for which he had paid $10,000, and that this entire amount was financed by the vendor. Lastly, the Appellant said that he later traded in the tow truck for vehicles that were added to his stock.
[46] Our tax system relies on the principle of self-assessment to function properly. Consequently, taxpayers play a decisive role, and the state assumes that citizens can take on this responsibility and the obligations inherent in it.
[47] To discharge this responsibility properly, citizens, particularly business operators, must put in place an accounting system that makes it possible to identify exactly which revenues are taxable. This involves a thorough accounting, not only for the sources of all income, but for the expenses as well. Furthermore, all relevant supporting documents must be made available.
[48] When this heavy responsibility is not taken seriously, and there is no way to carry out an audit in accordance with usual practices, the net worth method must be used. The principal weakness of this approach and this method is a certain degree of arbitrariness.
[49] Following a net worth assessment that was reasonably made and adequately supported and justified, a taxpayer is obviously entitled to register an objection. However, in the absence of reasonable and plausible explanations, the taxpayer risks having his or her appeal dismissed.
[50] The absence of accounting, or of records, books and supporting documents, can also have painful consequences for a negligent and careless person who has demonstrated indifference or recklessness. Indeed, the person may face penalties, assuming the Minister has met his burden of proving that the person has been careless or negligent to a certain degree, which depends on the type of the penalty.
[51] In the instant case, two kinds of penalties were imposed on the Appellant: one penalty is for filing his returns late, and the other is for failing to report income under circumstances amounting to gross negligence.
[52] It is indeed very difficult for a person claim that he has acted responsibly and with care when he cannot provide explanations, and especially documentation, in support of his statements. In the case at bar, the Appellant adduced no documentary evidence; his oral explanations were vague, incomplete or simply implausible.
The Appellant reported the following net income for the taxation years in issue:
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1996
1997
1998
1999
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$8,120.00
$6,950.80
$4,094.25
$8,309.00
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Exhibit A-17
Exhibit A-19
Exhibit A-21
Exhibit A-23
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On February 3, 2004, the Minister added the following amounts to the Appellant's income:
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Year
1996
1997
1998
1999
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Amount
$5,840
$5,586
$16,946
$17,138
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Percentage of reported income
72%
80%
414%
206%
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[53] The differences between the reported income and the attributed income are considerable. In addition, the Appellant is only contesting certain aspects of the net worth assessment.
[54] The difference between the declared assets and the assets determined using the net worth method is so significant that there is no doubt that the Appellant knowingly chose not to report a significant portion of his income. This is not an isolated oversight or mundane error. The divergence that has been found stems from a deliberate and unquestionably consistent and continuous intent to evade his tax obligations. The weakness of the arguments in support of the appeal show, once again, that the Appellant clearly had very little concern about the need to submit acceptable, let alone impeccable, records.
[55] The absence of supporting documentation, the essentially oral allegations, and certain implausible explanations (the source of the $10,000) are sufficient to show the extent to which the Appellant has made no effort, in the past or more recently, to implement any type of system that offers a minimum degree of consistency and reliability.
[56] In light of all these reasons, I find that the imposition of the penalties was appropriate and entirely justified. Setting them aside would have the effect of awarding carelessness and negligence.
[57] The appeal is allowed to the extent that the matter is referred back to the Minister for reconsideration and reassessment on the basis that the amount allocated to the Appellant's vacations must be removed from his expenses for the years in issue; in addition, the Minister shall take account of the fact that the tow truck purchased for $10,000 in 1996 has no effect on the Appellant's net worth for the years in issue.
[58] The penalties are confirmed on their merits, though they will have to be corrected in order to be consistent with the reassessments.
Signed at Ottawa, Canada, this 18th day of March 2005.
Tardif J.
Translation certified true
on this 19th day of October 2005.
Aveta Graham, Translator
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