Bell,
J.T.C.C.:—This
appeal,
respecting
the
1986
and
1987
taxation
years
of
the
appellant,
is
from
reassessments
which
added
the
sum
of
$37,821.88
to
his
1986
income
and
the
sum
of
$32,145.26
to
his
1987
income
pursuant
to
the
provisions
of
subsection
15(1)
of
the
Income
Tax
Act,
R.S.C.
1952,
c.
148
(am.
S.C.
1970-71-72,
c.
63)
(the
"Act")
and
which
added
the
sum
of
$41,846.03
to
his
1987
income
pursuant
to
the
provisions
of
subsection
15(2)
of
that
Act.
At
the
hearing
the
Court
was
advised
that
the
appellant's
income
would
be
reduced
by
certain
amounts
in
respect
of
various
designated
items.
As
a
result
of
negotiations
between
the
appellant
and
respondent
and
conclusions
made
by
me
the
amounts
added
to
income
by
the
reassessments
appealed
from
will
be
reduced
in
total
as
follows:
|
7
986
respecting
subsection
15(1)
of
the
Act
|
|
|
Respecting
missing
corporate
deposits
for
payments
received
on
|
|
|
account
|
$
6,617.44
|
|
Respecting
sale
of
bus
|
7,500.00
|
|
Respecting
personal
living
expenses
paid
by
Sat-Tech
Distributors
Inc.
|
|
|
(resident
expenses)
|
1,200.00
|
|
(personal
credit
card
charges)
|
1,573.00
|
|
Unvouched
expenses
considered
personal
|
6,701.00
|
|
Cheque
charged
to
casual
wages
deposited
by
shareholder
|
250.00
|
|
Vehicle
expense
paid
by
Sat-Tech
Distributors
Inc.
for
Unique
Auto
|
8,218.00
|
|
Total
|
$32,059.44
|
|
7
987
respecting
subsection
15(1)
of
the
Act
|
|
|
Missing
corporate
deposits
for
payments
received
on
account
|
$
7,214
|
|
Residence
expenses
|
1,100
|
|
Personal
credit
card
charges
|
1,700
|
|
Vehicle
expenses
paid
by
Sat-Tech
Distributors
Inc.
for
Unique
Auto
|
4,714
|
|
Welder
expenses
by
corporation
and
transferred
to
shareholders
|
1,725
|
|
Unvouched
expenses
considered
|
8,050
|
|
Total
|
$24,503
|
1987
respecting
subsection
15(2)
of
the
Act
Re
Shareholders
Loan
Account
Cash
paid
out:
non
deductible
|
(25
per
cent
of
$5568.18)
|
$
1,392
|
|
Cash
paid
out:
non
deductible
|
|
|
(25
per
cent
of
$6273.72)
|
1,568
|
|
Reduction
of
amount
included
in
income
under
subsection
15(2)
of
the
|
|
|
Income
Tax
Act
relating
to
reduction
of
debt
owing
by
H.
Osowsky
|
|
|
Enterprises
Ltd.
to
Sat-Tech
Distributors
Inc.
|
6,016
|
|
Total
|
$18,976
|
Appeal
allowed
in
part.
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