Brulé
T.C.J.
(orally):
Well,
this
situation
is
different
than
some
of
the
cases
where
it
has
been
mentioned
start-up
costs,
because
your
costs
each
year
were
relatively
the
same,
wages
and
janitorial
service.
It
wasn’t
like
a
farm
business
was
starting
up
to
make
money,
and
the
points
that
Mr.
Penton
made
are
very
valid,
that
I
think
the
money
was
staying
in
the
family
but
expenses
were
being
claimed
against
at
first
you
with
the
higher
wages,
and
later
on
outside
this
period
with
your
wife.
Now,
the
one
thing
I
will
mention,
and
there’s
no
question
in
my
mind
that
the
appeal
has
to
be
dismissed,
but
the
one
thing
I
want
you
to
take
note
of
is
that
this
thing
happens
the
odd
time
in
law,
and
section
111
of
the
Income
Tax
Act,
and
this
is
what
I
want
you
to
look
at
carefully,
gives
you
a
ten-year
window
in
which
you
can
claim
those
losses
that
were
disallowed
now
against
future
income.
So
you
can
get
them,
pick
them
all
up
if
your
business
is
successful
in
the
future,
and
you
claim
for
seven
years
back
and
three
years
forward
what
you
have
lost.
So
you
may
consider
that
and
make
sure
your
accountant
knows
about
it,
because
you
might
be
able
to,
if
you’re
successful
from
now
on,
you
seem
to
indicate
you
are,
you’ll
be
able
to
claim
all
your
losses
to
the
Court
and
on
your
tax
returns
in
the
future.
So
with
that,
I’ll
tell
you
that
that
is
a
possibility
for
you,
and
in
the
meantime
your
appeal
has
to
be
dismissed,
which
I
now
do.
Appeal
dismissed.
Email this Content