SIDNEY
SMITH,
D.J.:—The
appellant
appeals
from
a
decision
of
the
Income
Tax
Appeal
Board
dismissing
his
appeal
from
the
Minister
of
National
Revenue
on
assessments
for
1946
and
1947
income
tax
made
under
Section
47
of
the
Income
War
Tax
Act.
The
onus
rests
upon
appellant.
He
has
failed
to
satisfy
me,
on
the
evidence
now
adduced,
that
the
increase
in
his
net
worth
over
and
above
the
income
he
reported
was,
as
alleged,
due
to
betting
activities.
I
felt
I
was
not
being
told
the
whole
story.
I
respectfully
adopt
the
concluding
passage
in
the
judgment
of
the
Appeal
Board
in
the
present
case.
((1950)
2
Tax
A.B.C.
279
at
p.
283).
It
is
as
follows:
"However,
there
is
still
a
stronger
point
which
leads
me
to
dismiss
the
appeal.
I
have
said
in
other
decisions,
and
I
repeat,
that
I
do
not
consider
that
an
appellant
appealing
an
assessment
by
the
Minister
under
section
47
can
meet
the
onus
that
is
upon
him
by
a
general
statement,
unsupported
by
other
acceptable
evidence,
that
the
increase
in
his
net
worth
over
and
above
the
income
reported
is
due
to
betting
activities.
Again
a
general
statement
to
the
effect
that
he
thought
he
averaged
a
net
gain
of
$10,000
a
year
in
these
activities
is
not
in
my
opinion
sufficient
to
meet
the
onus
referred
to.
The
Board
has
met
such
a
plea
on
several
occasions
and
it
would
appear
to
me
to
open
wide
the
doors
to
tax
evasion
if
such
an
unsupported
statement
were
accepted
as
meeting
and
overriding
the
presumption
of
validity
attributed
to
an
assessment
by
the
Minister.
‘
‘
The
appeal
is
dismissed
with
costs.
Appeal
dismissed.
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