Docket: 2018-1534(IT)G

BETWEEN:

ESTATE OF THE LATE GEORGES ROBILLARD,

Appellant,

and

HER MAJESTY THE QUEEN,

Respondent.

[OFFICIAL ENGLISH TRANSLATION]

Appeal heard on common evidence with the appeal of the estate of the late Georges Robillard (2018‑1536(IT)G),

on November 29 and 30, 2021, at Montreal, Quebec

Before: The Honourable Justice Robert J. Hogan

Appearances:

AMENDED JUDGMENT

For the following reasons, the appellant’s appeal against the assessment for tax year 2012 is dismissed.

The parties will have until February 14, 2022 to reach an agreement on costs, failing which they are directed to file their written submissions on costs no later than February 15, 2022. The submissions are not to exceed 10 pages.

Signed at Ottawa, Canada, this 27th day of January 2022.

"Robert J. Hogan"

Translation certified true

on this 9th day of February 2022.

François Brunet, Revisor

Citation: 2022 TCC 17

Date: 20220127

Docket: 2018-1534(IT)G

BETWEEN:

ESTATE OF THE LATE GEORGES ROBILLARD,

Appellant,

and

HER MAJESTY THE QUEEN,

Respondent.

[OFFICIAL ENGLISH TRANSLATION]

AMENDED REASONS FOR JUDGMENT

Hogan J.

I. Introduction

[1] On April 27, 2021, the appellant filed a notice of appeal with the Tax Court of Canada.

[2] The appellant argued that a capital loss of $141,564 resulted from a redemption. This loss was deferred in the late Georges Robillard’s final return.

[3] In the notice of assessment issued on March 30, 2016, the Minister set the amount of this capital loss at $68,442.

[4] At the hearing, the appellant discontinued its appeal on the issue of the $141,564 capital loss having been deferred in the late Georges Robillard’s final return.

II. Conclusion

[5] For the aforementioned reasons, the appellant’s appeal against the assessment for tax year 2012 is dismissed.

Signed at Ottawa, Canada, this 27th day of January 2022.

"Robert J. Hogan"

Translation certified true

on this 9th day of February 2022.

François Brunet, Revisor

APPEARANCES:

COUNSEL OF RECORD:

For the Appellant: