Hokhold – Federal Court of Appeal finds that a bad debt claim requires the specific identification of which “debt” claims went bad

Partly as a delayed consequence of CRA’s seizure of computers and dental equipment of a dental practice and the misplacing of records when his practice subsequently was closed, the dentist was only able to collect a portion of the revenues that he had included in his 2005 to 2008 returns. However, the Tax Court found that he was not entitled to a bad debt deduction on the basis inter alia that he was unable to identify which specific debts had gone bad. In agreeing with this finding, and before going on to dismiss the appeal, Boivin JA stated:

[I]n order to have a “liquidated money demand, recoverable by action” one must know the identity of the debtor and the amount owed … .

Neal Armstrong. Summary of Hokhold v. Canada, 2018 FCA 163 under s. 20(1)(p)(i).