Guy
Tremblay
[TRANSLATION]:—The
case
at
bar
was
heard
at
Quebec
City
on
May
13,
1977.
1.
Point
at
Issue
The
issue
is,
first,
whether
the
sum
of
$37,803.56
is
deductible
in
computing
the
income
of
the
appellant,
a
contractor
from
Les
Hauteurs,
Rimouski
County,
Quebec.
The
said
sum
is
the
total
of
various
deductions
over
1971,
1972,
1973
and
1974.
It
must
also
be
determined
whether
a
penalty
imposed
by
the
respondent
equal
to
25%
of
the
extra
tax
assessed
should
be
applied.
2.
Settlement
After
hearing
the
evidence
submitted
by
the
appellant
and
part
of
the
evidence
of
the
respondent,
the
parties
agreed
to
settle
the
matter
as
follows:
(a)
of
the
$37,803.56
refused
by
the
respondent
for
the
four
years
concerned,
half
will
be
allowed
as
a
deduction
in
computing
the
appellant’s
net
income;
(b)
the
25%
penalty
will
be
applied,
but
only
after
the
new
calculation
of
income
tax.
3.
Conclusion
The
appeal
is
allowed
in
part
and
the
matter
is
referred
back
to
the
respondent
for
reassessment
in
accordance
with
the
above
agreement.
Appeal
allowed
in
part.
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