D E Taylor:—These appeals were heard on common evidence in the City of Toronto, Ontario, on February 19,1980, and the issue in each case is identical, although there is a slight difference in the amounts involved. The appeals are against income tax assessments for the year 1975 in which the Minister of National Revenue provided the following information in making changes:
Lynne Judith Salsberg
Your capital loss has been reduced by $81.20.
Your interest income has been reduced by $1,062.77.
Your carrying charges have been reduced by $1,054.13.
Your interest and dividend income deduction has been reduced by $980.79 as there was no bona fide acquisition or disposition of the bonds.
Eric Paul Salsberg
Your Capital Loss has been reduced by $69.60.
Your interest income has been reduced by $1,054.13.
Your carrying charges have been reduced by $1,028.21.
Your interest and dividend income deduction has been reduced by $745.81 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
Eric Paul Salsberg was a solicitor by profession and Lynne Judith Salsberg was a teacher by profession. In all aspects relevant to a determination of these appeals, the issue is identical to that in the appeals 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 appeals are dismissed.
Appeals dismissed.
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