Bonner,
T.C.J.:—The
appellant,
in
his
returns
of
income
for
the
1980,
1981
and
1982
taxation
years,
claimed
deductions
under
paragraph
109(1)(d)
of
the
Income
Tax
Act
in
respect
of
his
children,
Jonathan
and
Daniel.
The
respondent,
in
assessing
tax
for
the
1981
and
1982
taxation
years,
disallowed
the
deductions.
The
appellant
appeals
from
those
assessments.
The
respondent
assessed
no
tax
for
the
1980
taxation
year.
Although
the
appellant
brought
an
appeal
in
respect
of
that
year,
there
is
no
relief
which
this
Court
can
give
from
a
"nil
assessment
.
The
1980
appeal
must,
therefore,
be
dismissed.
It
may
be
helpful
to
note
that
paragraph
109(1)(d)
of
the
Act
authorizes
deductions
only
in
respect
of
children
wholly
dependent
for
support
on
the
taxpayer.
The
appellant’s
evidence
made
it
quite
clear
that
although
he
supported
the
children,
their
mother
also
supported
them.
In
the
circumstances
the
appeals
for
the
1981
and
1982
years
must
also
be
dismissed.
Appeals
dismissed.
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