D E Taylor:—This is an appeal heard at a special sitting of the Board held in the City of Toronto, Ontario, on February 19, 1980 against an income tax assessment for the year 1975 in which the Minister of National Revenue gave the following explanation for changes:
Your Capital Loss has been reduced by $ Nil.
Your interest income has been reduced by $1,026.12.
Your carrying charges have been reduced by $1,017.78.
Your interest and dividend income deduction has been reduced by $1,000, as there was no bona fide acquisition or disposition of the bonds.
In so assessing, the respondent relied, inter alia, upon section 3, subsection 9(1), paragraph 12(1)(c), subsection 20(14) and section 110.1 of the Income Tax Act, SC 1970-71-72, c 63, as amended.
Facts
The appellant is a solicitor by profession. In all aspects relevant to a determination of this appeal, the matter is identical to that of Gordon R Baker and Kathryn E Baker v MNR. No evidence of transfer of the securities for purposes of subsection 20(14) of the Act was provided.
Decision
The appeal is dismissed.
Appeal dismissed.
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