Taylor
T.C
J
.:
These
appeals
were
heard
in
Toronto,
Ontario
on
December
2,
1996,
against
the
disallowance
of
the
claim
primarily
for
rental
losses,
although
certain
capital
and
terminal
losses
constituted
part
of
the
disputed
assessments.
The
Appellant,
a
lawyer
by
profession,
presented
complete
and
detailed
information
in
support
of
the
appeals,
but
in
my
view
that
material
only
tended
to
substantiate
the
reasons
for
the
Respondent’s
disallowance
of
the
claim.
I
need
not
record
in
these
reasons
the
data
from
the
Notice
of
Appeal
or
the
Reply
to
Notice
of
Appeal,
but
a
reading
of
them
is
necessary
to
properly
understand
the
situation.
Short
reasons
were
provided
in
Court
for
dismissing
the
appeals,
and
in
doing
so
without
the
Court
considering
it
necessary
to
hear
from
Counsel
for
the
Respondent
in
the
matter.
In
summary
the
issue
was
the
“personal
use”
of
the
real
estate
property
by
the
Appellant,
a
point
cogently
noted
by
the
learned
Justices
in
Tonn
v.
R.,
[1996]
1
C.T.C.
205,
96
D.T.C.
6001
(Fed.
C.A.).
Certain
portions
of
a
recent
judgment
from
the
Court
-
Sardinha
v.
R,
(November
29,
1996),
Doc.
96-860(IT)I
(T.C.C.)
were
read
to
the
Appellant
in
Court
which
dealt
with
this
specific
point
which
sometimes
arises
in
such
asserted
“rental
loss”
matters.
The
appeals
are
dismissed.
Appeal
dismissed.
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