The
Chairman:—This
is
the
appeal
of
Siranouche
Karadjian
from
reassessments
dated
December
16,
1974,
in
respect
of
the
appellant’s
income
for
the
1969,
1970,
1971,
1972
and
1973
taxation
years.
This
appeal
was
heard
on
common
evidence
with
the
appeal
of
her
father,
Edward
Djoboulian,
being
appeal
No
76-537.
The
facts
and
the
issue
in
the
instant
appeal
are
related
to
those
in
the
Edward
Djoboulian
appeal
and
the
reasons
for
judgment
in
that
appeal
are
applicable
in
determining
the
present
issue
mutatis
mutandis.
Contentions
The
appellant
contends
that
the
Minister’s
net
worth
assessment
of
her
income
for
the
pertinent
taxation
years
contained
several
errors
which
understated
her
capital
assets
as
at
December
31,1968
and
overstated
her
net
capital
assets
as
at
December
31,
1973.
The
appellant
also
contends
that
the
Minister
overstated
her
personal
living
expenses
for
the
years
1969
to
1973.
The
appellant
further
contends
that
the
Minister
in
his
net
worth
assessment
did
not
take
into
account
capital
receipts
which
she
received
as
a
gift
from
her
father
each
time
the
latter
received
capital
payments
from
a
source
of
his
own
money
in
Egypt
and
which
were
brought
to
him
through
the
intermediary
of
several
persons
arriving
from
Egypt.
In
deciding
the
appeal
of
Edward
Djoboulian,
the
Board
accepted
certain
capital
receipts
from
Egypt
as
being
part
of
his
financial
resources
which
it
considered
as
constituting
part
of
his
capital
assets
as
at
December
31,
1973.
These
same
capital
receipts
cannot
now
be
considered
as
also
constituting
part
of
the
appellant’s
capital
assets
as
at
that
date.
The
onus
of
establishing
her
other
contentions
to
the
satisfaction
of
the
Board
rests
on
the
appellant.
This
she
failed
to
do.
No
evidence
was
adduced
in
support
of
her
allegations
in
respect
of
her
net
worth
assessments
and
she
did
not
refute
the
Minister’s
assumption
of
facts
in
making
his
assessments.
Decision
The
Board
finds
that
the
facts
on
which
the
Minister
based
his
asessments
were
not
refuted
by
the
appellant
and
that
the
Minister
did
not
err
in
assessing
the
appellant
on
a
net
worth
basis.
The
appeal
must,
therefore,
be
dismissed.
Email this Content