Date: 20000918
Docket: 98-2426-IT-G
BETWEEN:
RABAH ABDERRAHMAN,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent,
AND
Docket: 98-2381-IT-G
BETWEEN:
RESTAURANT KERKENNAH INC.,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
Reasonsfor
Judgment
Lamarre Proulx, J.T.C.C.
[1]
These appeals were heard on common evidence. Net worth
assessments were made against the individual appellant for the
1991, 1992 and 1993 taxation years. Additional income of $22,863,
$22,579 and $22,424 respectively was added to his income for the
years at issue, and penalties of $2,938.35, $2,898.53 and
$1,846.27 respectively were assessed under subsection 163(2) of
the Income Tax Act ("the Act"). According
to the Minister of National Revenue
("the Minister"), the same amounts must be added
to the corporate appellant's income since the individual
appellant has no known sources of income other than the corporate
appellant's restaurant and he is the sole shareholder of the
corporate appellant. However, in view of certain minor
adjustments that are not at issue, the amounts added are $23,478,
$23,210 and $22,424 respectively. The penalties are $1,507.28,
$1,466.97 and $1,439.62.
[2]
The individual appellant's net worth was established by
Revenue Quebec officials.
[3]
At the start of the hearing, counsel for the appellants told the
Court which points the appellants wished to elaborate on.
[4]
With regard to the individual appellant, counsel argued that
$17,000 should be deducted from the income added for 1991.
Counsel stated that, at the objection stage in Quebec, $17,000
was added to the individual appellant's assets for the year
ending on December 31, 1990. A difference of $6,478 would
therefore remain for 1991. For 1992, counsel endeavoured to show
that a gift of $30,000 was made to the individual appellant by
his mother that year. That gift was also said to have been
acknowledged by Revenue Quebec. For 1992, there would thus be no
difference. For 1993, the $22,424 in added income is not being
contested. For that year, the only dispute concerns the
penalties. As Exhibit A-12, counsel for the appellants
filed a working paper containing a table showing these
calculations.
[5]
The penalties are being contested for both appellants for the
various years at issue on the basis that the Minister may not
delegate his discretion to assess penalties.
[6]
With respect to the corporate appellant, counsel argued that the
restaurant's accounting was satisfactory and that its
reported income was its real income. The net worth method cannot
be used when a person's accounting is adequate. In any event,
counsel for the corporate appellant argued that the individual
appellant's income was from a source other than the
restaurant, namely the tips received by his spouse.
[7]
At the start of the hearing, counsel for the respondent told the
Court that, since the corporate appellant's fiscal year ends
at the end of August, the Minister is now of the opinion that
only a prorated share of the income not reported by the
individual appellant for 1991 must be added to its income, namely
an amount of $7,825 rather than $23,478. The penalties will be
adjusted accordingly.
[8]
The individual appellant, his mother, Fatma Ben Salah Elmekki,
and his wife, Souad Abderrahman, testified for the appellants.
Réjean Michaud and Anne Frenette testified for the
respondent.
Testimony of the individual
appellant
[9]
The individual appellant is a Canadian citizen who was born in
Tunisia. He arrived in Canada in 1967 for Expo to take part in
presenting his country's cuisine. He began working in Canada
in 1968 in the restaurant business. He opened the corporate
appellant's restaurant in 1974. It seats 40 and serves
Tunisian specialties. Two people worked there during the years at
issue, namely the individual appellant and his wife, Souad
Abderrahman. The individual appellant is responsible for going to
the market and doing the cooking, while his wife takes care of
the tables and the cash register. She is the one who sees to the
bookkeeping. She gives the information to the accountant, a Mr.
Weiser, once a month. It is he who keeps the books, in
computerized form, and these were filed as Exhibit A-7. It is
also the accountant who determines the amounts to be paid to the
government authorities. The individual appellant and his wife
write the appropriate cheques.
[10] The books
were given to the Revenue Quebec auditor, Mr. Michaud, when he
came. He apparently conducted his audit at the accountant's
office. He also obtained the sales invoices, cash register tapes
and other documents. He then asked to see the personal bank
accounts of the individual appellant and his wife. Powers of
attorney were granted by both of them and were filed as Exhibits
I-1 and I-8.
[11] According
to the individual appellant, his mother does not speak or
understand French. She never went to school. She comes from
Kerkennah Island. She is 84 years old. The individual
appellant's father worked in Sfax, a large city near
Kerkennah.
[12] Exhibit
A-13 is a photocopy of an ownership certificate for a
Canada savings bond. According to the individual appellant, it
was a $7,000 bond and he cashed it in on May 1, 1990. The $7,000
was deposited in a safety deposit box at the
Caisse St-Paul-de-la-Croix. Interest in the amount of
$367.50 was deposited in his personal account (number 9671), as
confirmed by Exhibit A-14, which is a computerized bank
statement. Exhibit A-15 is a $10,000 Canada savings bond. It was
cashed on November 1, 1990, and the money was also deposited in
the safety deposit box. According to the individual appellant,
the above amounts, which totalled $17,000, were still in the
safety deposit box at the start of 1991.
[13] The
individual appellant explained that his mother gave him $30,000
in 1992 so that he could purchase a motor home. That amount was
kept in the safety deposit box.
[14] Those two
amounts were accepted by Revenue Quebec. Exhibit A-16 is a
settlement proposal made by the Revenue Canada appeals officer
offering the same settlement basis as had been granted by Revenue
Quebec. In that letter, which is dated September 15, 1997, the
signatory explained to the appellants' representative that,
if the offer was not accepted, Revenue Quebec's files would
be requested and Revenue Canada's decision might then not be
as favourable as Revenue Quebec's. Counsel for the respondent
objected to the filing of that proposal on grounds of relevance.
The proposal was as follows:
[TRANSLATION]
. . .
Subject
Your notices of objection for the 1991-92-93 taxation years
Rabah Abderrahman S.I.N. 230-722-530
Restaurant Kerkennah Inc. Corp. # 103061297RC
Dear Sir:
Further to our telephone conversation of September 11, 1997,
this is to confirm our settlement offer concerning the objections
for the above-mentioned taxpayers.
Since the Government of Quebec has conducted the audit and the
regional objections directorate has revised its assessments to
the following amounts, it seemed fair to us to make you the same
settlement offer as the provincial government, namely the
following amounts:
1991
1992
1993
Rabah
Abderrahman
$17,538
$4,770
$22,424
Restaurant Kerkennah
Inc.
$5,552
$0
$22,424
Since you are not in agreement, at the federal level, with the
amounts proposed, we must get the files concerned from the
provincial government so that we can analyse the claims you make
in your notices of objection.
If the new settlement offer is not to your advantage, we will
not be able to return to the above-mentioned offer and we will
have to assess on the basis of the new results.
[15] According
to the individual appellant, his representative did not inform
him of that offer.
[16] On
cross-examination, the individual appellant said that he does not
receive a salary from the restaurant. He has rental income and
that is what he reports. He thinks that his wife earns about
$12,000 a year for her work at the restaurant, although he
suggested that the accountant should be asked about the amount of
her salary, since he himself was not sure. He said that that is
not his field, that his field is cooking. He signs a cheque for
his wife each month. The amount of the cheque varies, but it is a
little more than $1,000 a month.
[17] Taking
Exhibit A-12, the calculations in which are described in
paragraph 4 of these Reasons, counsel for the respondent
asked the individual appellant to explain his assertion that the
differences in income came from his wife's tips and not from
the restaurant. In 1991, total sales were $109,720 according to
the combined statement of income and retained earnings that is
part of Exhibit A-1. With respect to that amount, the tips were
allegedly $6,478. In 1992, sales amounted to $101,946
(Exhibit A-2), and the tips received were allegedly
$6,790. In 1993, sales amounted to $89,963 (Exhibit A-3), and the
tips were allegedly $22,424.
[18] The
individual appellant also said that his mother might spend three
months in Canada and nine months in Tunisia but sometimes she
stayed in Canada longer. His mother has permanent resident
status. She has filed income tax returns in Canada. In 1990, she
filed a return in which she reported $5,000 in employment income.
In 1991 and 1992, the individual appellant claimed his mother as
a dependant and his father as a dependant with a disability.
[19] He said
that, after the death of a second brother, his mother told him to
[TRANSLATION] "make the most of life". She gives him
money in amounts sometimes of $1,000 and sometimes of $2,000. She
brings it over in Canadian currency. His mother is very well off
in Tunisia. She has houses that she rents. She has lands that she
farms. She sells produce. She earns income.
[20] The
individual appellant's notice of appeal to Revenue Quebec was
filed as Exhibit I-5. His then counsel therein explained the
source of the $30,000 as follows:
[TRANSLATION]
(d)
as a result of litigation, the objector received $30,000.00 in
full and final settlement, and that amount cannot be considered
income under any circumstances.
[21] Counsel
for the respondent asked the individual appellant which version
was correct. He answered that he did not even know what
"litigation" meant. In redirect examination, he claimed
that his counsel had not given him the document to read.
Testimony of the appellant's mother
[22] Fatma Ben
Salah Elmekki is a farmer. She grows grapevines and fig trees.
She is very busy. She lives with her three sons, Mohamed, Rabah
and Gemma, who are all in Canada. At the moment she is staying
with Mohamed, who lives in Laval. In Tunisia, she lived in Sfax.
She has a house there and two in Kerkennah. She lives in Tunisia
more often because she has business there. She cannot read or
write. She does not even know how to count Canadian money. Her
husband worked in a hotel in Sfax. She has been giving her son
money for 21 years. How much money did she give Rabah? $30,000.
She gave that money to him and not the others because he is going
to let the others use his motor home. She took out money until he
told her it was enough. She gave him the money personally. She
does not remember getting a certificate from a Tunisian bank
dated March 25, 1996 (Exhibit A-18) stating that she
kept a considerable amount of money there. She said that she
withdrew her money from all banks 12 or 13 years ago, after a
trip to Mecca, because, according to her, the Muslim religion
does not allow interest to be made on one's capital.
[23] Exhibit
I-7 is a sworn statement dated July 5, 1995, to the effect that
she gave the appellant $30,000 on May 16, 1992, [TRANSLATION]
"as a [gift] when I travelled to Canada upon the death of
my son Hassan, who also lived in Canada". In that
statement, she identified herself by her Canadian passport. Yet
Exhibit I-6, which is her passport, shows that she arrived in
Carthage on May 13, 1992.
Testimony of the individual
appellant's spouse
[24] Souad
Abderrahman has been living in Canada for 23 years. She is
Tunisian and is from Kerkennah Island. She was born in Sfax. She
is the one who looks after the restaurant's accounting: the
sales, the cash register, the invoices. Her husband's role is
in the kitchen and making purchases. He prepares and signs
cheques at her request. She prepares the invoices to be paid.
[25] She
balances the cash every Monday. At the end of each month, the
cash register tapes, the invoices, including those paid in cash,
and the take from the cash register are put in an envelope and
sent to the accountant, Mr. Weiser. At the same time, she fills
out a form noting the purchases made for the kitchen as well as
sales, meals, wine and taxes.
[26] As
Exhibit A-21, Souad Abderrahman filed a cash report with invoices
attached. That report is prepared once a month and sent to the
accountant.
[27] It was
not Mr. Weiser who met with Mr. Michaud, the Minister's
auditor. It was Rached Ghanem. During the audit, the
invoices and cash register tapes were brought to the accountant
at his request. When Mr. Michaud went to the restaurant with
Rached Ghanem, neither the witness nor her husband sat down
with them.
[28] She said
that her tips might amount to about $4,000 a year. She set the
rate at eight to ten percent of sales. She gives the tips to her
husband.
[29] She was
the one who cashed the $7,000 bond on May 1, 1990. She put the
money in her safety deposit box at the Caisse populaire
St-Paul-de-la-Croix. She deposited the interest in her
husband's account. It was also she who cashed the bond that
was Exhibit A-15, on November 1, 1990, and put the money in
the safety deposit box.
[30] Exhibit
A-17 is made up of photocopies of signatures of the person
authorized to have access to the safety deposit box. Mrs.
Abderrahman claimed that she took cash out each time to pay for
the motor homes. Exhibit I-3 is a document evidencing the
purchase of the first motor home, while Exhibit I-4 is for the
second. The first document is dated August 7, 1992 and the
delivery date was August 14, 1992. She went to the
safety deposit box on August 7, 1992. The document indicates that
a $32,000 cash deposit was made on August 10, 1992. The
second purchase contract is dated August 17, 1993. Thirty
thousand dollars in cash was paid on September 21, 1993. Mrs.
Abderrahman went to her safety deposit box on September 20,
1993.
Testimony of the auditor
[31]
Réjean Michaud is now an objections officer for
Revenue Quebec. At the time of the audit, according to his report
(Exhibit I-9), he was working for the audits and investigations
branch. He explained that a decision to use the net worth method
is made following a brief analysis at the office based on a
comparison of the assets acquired and the income reported The
assets in this case were the bank investments, the motor vehicles
and the immovable property. The auditor then met with the
individual taxpayer and asked him whether he had any
non-taxable sources of income. In this connection, the
individual appellant asked the auditor to meet with Alain
Brisebois, his accountant. Mr. Brisebois answered the question in
the negative.
[32] According
to the auditor, the type of business involved is one in which
there are many cash transactions, which makes it more difficult
to validate reported income using accounting records. As well,
the corporation is one with a sole shareholder.
[33] In
drawing up the balance sheet as at December 31, 1990, the auditor
did not take into account the cashing of a $7,000 savings bond on
May 1, 1990. That investment no longer existed on
December 31, 1990, because it had been cashed in May 1990. The
money may still have existed on December 31, 1990, but it could
very well have been in the substantial bank account balances or
the other assets found on the opening balance sheet. As for the
$10,000 bond allegedly cashed in November 1990 (Tab 20), it could
not be determined whether a bond had been cashed or when. No
mention was ever made to him of a gift of $30,000 during his
investigation. Nor was a safety deposit box ever referred to
during the audit.
[34] The
auditor concluded that the unreported income came from the
restaurant because there was no indication of any other source of
income.
[35] The
proposed assessment was submitted to Serge Racine. The auditor
later met with Mr. Ghanem, who made representations to him. That
meeting took place at the restaurant. The individual appellant
was at the meeting. During the meeting, Mr. Ghanem agreed
with almost every point except the matter of the unexplained
Canada savings bond withdrawals of $10,000 in 1992 and $12,000 in
1993 referred to in Schedule A to the Reply to the Notice of
Appeal concerning the individual appellant. There was no
explanation of how those withdrawals had been used. The
withdrawals were accepted at the objection stage and are not in
dispute.
[36] On
cross-examination, Mr. Michaud said that he did not think that
Mr. Brisebois worked for Mr. Weiser, the accountant. He
worked alone in the basement of his home. Mr. Michaud examined
the restaurant's books and gave them a satisfactory rating in
his report. The restaurant's accounting system was complete.
With regard to sales, there were the cash register tapes. Outlays
could be made by cheque. The reported income was established
through the bank deposits. The financial reports had been
prepared by Mr. Weiser. Mr. Michaud never had any contact
with that accountant, who had not checked the accounting.
[37] On
cross-examination, Mr. Michaud admitted that, in net worth
auditing, it is almost impossible to identify the source of
unreported income with absolute certainty. There was never any
business discussion with Mr. Abderrahman. Income from tips was
not mentioned during his audit.
[38] Anne
Frenette is an objections officer at the Canada Customs and
Revenue Agency. Her reports were filed as Exhibits I-10 and I-11.
She had to discuss the appellants' files with Raymond
Tremblay, an accountant, who represented the individual taxpayer
at the objection stage. She refused to take the $30,000 gift into
account because there was too much confusion about the
circumstances of the gift to give credence to the contention that
there was a gift. The accountant said that Ms. Elmekki lived in
Canada or was a resident of Canada. Mr. Abderrahman said that his
mother had not lived in the country for 10 years. However, in his
tax returns, he claimed his parents as dependants. Ms. Elmekki
had a social insurance number in Canada and filed tax returns in
1991 and 1992. Based on those returns, she seemed to be living in
Canada at the same address as the individual appellant. There
were years when she filed returns and others when she did not.
She filed a $1 return each year.
[39] Ms.
Frenette did not take the $17,000 into account either. According
to Mr. Tremblay, that $17,000 was money in hand that had been put
in a safety deposit box at the bank. This aspect of the case had
never been mentioned prior to the notice of objection stage.
Moreover, since she could not find out the amounts in the safety
deposit box for the subsequent years, she did not allow the
amount for the first year.
[40] The
objections officer said that she was never given any explanation
concerning the tips. The notice of objection stated that the
money in question was accumulated personal savings.
Argument of counsel for the appellants
[41] As
regards the penalties, counsel argued that the Minister cannot
rely on an audit done by Revenue Quebec to discharge his burden
of proof.
[42] With
regard to the corporate appellant, counsel for the appellants
argued that the net worth method cannot be used where there is
satisfactory accounting. He relied on decisions explaining that
recourse to the net worth method is not the rule and that it is
to be used exceptionally, in cases where adequate accounts have
not been kept.
[43] Counsel
realized that the net worth method was used not against the
restaurant but against the individual appellant. The Minister
added income amounts of the individual appellant as coming from
the restaurant because, in his view, there was no other plausible
explanation of the source of the additional amounts. Yet there is
no evidence showing that the individual appellant or his wife
appropriated the corporation's income. There is no evidence
that the restaurant could have generated additional income.
According to counsel for the corporate appellant, the tips earned
by his wife are the source of the individual appellant's
additional income, in addition to the amounts of $17,000 and
$30,000 referred to.
[44] As
regards the individual appellant, counsel's working paper
(Exhibit A-12) explains the changes he argues should
be made to the net worth established by the Minister. For 1991,
$17,000 should be deducted, resulting in an adjusted additional
income of $6,478. For 1992, there would be no additional income
given the $30,000 gift from the individual appellant's
mother. The individual appellant is not contesting anything with
respect to 1993. The source of the balances remaining is the tips
earned by the individual appellant's wife.
[45] With
respect to the $30,000, counsel for the respondent argued that
the evidence did not show when in 1992 that amount was given.
There is no information on that. Moreover, the gift was never
mentioned during the audit. It was mentioned for the first time
to Revenue Quebec at the objection stage, and according to the
document filed, the individual taxpayer's representative
referred to a settlement of litigation, which settlement Mr.
Abderrahman has denied. Nothing certain can be taken from the
testimony of the individual appellant's mother. She said that
she does not deal with banks, yet there was entered in evidence a
bank certificate from the Société tunisienne des
banques (Exhibit A-18). As for the sworn statement, it was the
individual appellant who prepared the document and asked her to
sign it. Although she allegedly made the gift in Canada on
May 16, 1992, her passport shows that she arrived at
the Tunis Carla airport on May 13, 1992. She was therefore
in Tunisia and not Canada on May 16, 1992.
[46] As
regards the corporate appellant, counsel for the respondent
argued that there is no plausible source of income other than the
restaurant. She also argued that the income from tips was never
reported by either Mr. or Mrs. Abderrahman.
Mrs. Abderrahman said that her income totalled $4,000 a
year.
Conclusion
[47] The
settlement offer filed as Exhibit A-16 was objected to by the
respondent on the ground that it was not relevant to the legal
debate, as mentioned in paragraph 14 of these Reasons. Privilege
was not raised. I will therefore decide on the basis of
relevance. Counsel for the appellants argued that the offer was
relevant because the audit was done by Revenue Quebec and
everything allowed by Revenue Quebec should also be allowed by
the Minister. It is my view that the document may have been
relevant if the amounts allowed had been allowed for reasons
related to the facts or the Act that were explained in the
offer or another attached document. The amounts were allowed
solely to settle the dispute, and that was also why they were
proposed to the individual taxpayer. That offer is therefore of
no use to the debate herein and in that sense it is not relevant.
The individual appellant said that his representative did not
tell him of the offer. This is therefore a matter between him and
his representative.
[48] The
inclusion of the $17,000 in the individual appellant's assets
as at December 31, 1990, was denied for various reasons: the
amount from the cashing of two bonds could have been used to
acquire or increase the assets already taken into account; there
was no documentary evidence that the second bond, in the amount
of $10,000, had been cashed; if there was $17,000 in cash in the
safety deposit box at some point, this was customary
behaviour—there are amounts each year and they must be
reported; the individual appellant did not provide these details
for the other years. In my view, these reasons for the denial are
reasonable.
[49] The
inclusion of the $30,000 gift in non-taxable income was denied
for the year ending on December 31, 1992, on the ground that
there was no consistent evidence on this: the notice of appeal to
Revenue Quebec dated September 26, 1995, states that
the amount was received in final settlement of litigation; the
individual appellant was unable to explain that allegation; the
evidence showed that the individual appellant's mother is a
woman of considerable financial means, yet he claimed her as a
dependant in his income tax returns. In the testimony given by
the various witnesses, reference was made to gifts of a thousand
dollars at a time over the years, but also to an amount of
exactly $30,000 given all at once; at the audit stage, no one
mentioned the $30,000 gift. In my opinion, the weight of the
evidence is not such as to enable me to conclude that a gift of
$30,000 was made in 1992.
[50] Does the
individual appellant's unreported income come from the
operation of the corporate appellant's restaurant? The
individual appellant has suggested the tips received by his wife
as another plausible source of income. It is true that net worth
takes account of family income, that is, in this case, the
individual appellant's income and his wife's income. This
is agreed on by both parties. However, the wife did not report
tips as a source of income. The income taken into account in the
individual appellant's net worth is the income reported by
him and his wife. Thus, with regard to the individual appellant,
the income from tips cannot reduce the difference between the
reported and the unreported income.
[51] Given the
significant differences between the reported and the unreported
income, it is my view that the penalties assessed under
subsection 163(2) of the Act were correctly assessed.
Counsel for the appellants' initial argument that the
Minister was not the one who had exercised his discretion in
assessing the penalties was not really discussed in depth since
the evidence showed that it was the Minister's own officials,
and not those of Revenue Quebec, who considered the assessment of
penalties and then assessed them.
[52] Counsel
for the corporate appellant argued that that appellant kept
satisfactory accounts and that no assessment should be made
against it on the basis of the net worth established with respect
to its shareholder. However, I can only note that there was no
definite evidence that the income reported by the corporate
appellant was its only income. Its accounting was not analysed
exhaustively. As suggested by the respondent, there is also a
possibility in this type of business that cash sales are not all
reported. With such a business, where the principal shareholder
has not reported all of his or her income and has no explanation
of the source of that income, the Minister is entitled to assess
the business as being the source of the income in question. On
this point, see, inter alia, Fortis et al. v. Minister
of National Revenue, 86 DTC 1795; Chicken Tandoor Limited
and Monahar Lal Ahir v. Minister of National Revenue,
87 DTC 487; Maison Funéraire Robichaud Ltée
and Camille Robichaud v. The Queen, 97 DTC 491; and
Luso Construction Ltd. v. Canada, [1999] T.C.J.
No. 323.
[53] It was
therefore up to the individual appellant to give a reasonable
explanation of the source of the unreported income. He did so in
part by referring to the tips. His wife calculated that she might
have received $4,000 in tips in those years, which I consider
plausible. In my opinion, that is another plausible source of
income. As for the balance, there is no reasonably acceptable
explanation other than that the income came from the restaurant.
Accordingly, the additional income added by the Minister, aside
from the $4,000 amounts mentioned above, was correctly added as
unreported income to the corporate appellant's reported
income.
[54] The
penalties must be upheld for the same reasons as were given with
respect to the individual appellant.
[55] The
individual appellant's appeals are dismissed with costs. The
corporate appellant's appeals are allowed, without costs, on
the basis of what is stated in paragraphs 53 and 54 of these
Reasons and the respondent's admission as set out in
paragraph 7 of these Reasons.
Signed at Ottawa, Canada, this 18th day of September 2000.
"Louise Lamarre Proulx"
J.T.C.C.
[OFFICIAL ENGLISH TRANSLATION]
[OFFICIAL ENGLISH TRANSLATION]
98-2426(IT)G
BETWEEN:
RABAH ABDERRAHMAN,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
Appeals heard on common evidence with the
appeals of Restaurant Kerkennah
Inc.
(98-2381(IT)G) on May 29 and 30, 2000, at
Montréal, Quebec, by the Honourable Judge Louise
Lamarre Proulx
Appearances
Counsel for the
Appellant:
Yves Ouellette
Reno Vaillancourt
Counsel for the
Respondent
Anne-Marie Boutin
Mounes Ayadi
JUDGMENT
The
appeals from the assessments made under the Income Tax Act
for the 1991, 1992 and 1993 taxation years are dismissed, with
costs, in accordance with the attached Reasons for Judgment.
Signed at Ottawa, Canada, this 18th day of September 2000.
J.T.C.C.
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