A
J
Frost:—This
is
an
appeal
from
a
reassessment
dated
May
20,
1971
in
respect
of
the
appellant’s
1969
taxation
year.
It
was
heard
at
Belleville,
Ontario
on
December
14,
1971
by
the
Tax
Appeal
Board
as
it
was
then
constituted.
The
question
in
issue
is
whether
or
not
the
appellant
was
in
the
business
of
farming
with
a
reasonable
expectation
of
profit
during
the
year
1969.
The
appellant
testified
that
during
that
year
he
was
carrying
on
a
farm
operation
and
that
the
main
area
of
the
farming
operation
was
a
family
farm
established
by
his
grandfather
in
the
1800’s.
He
claimed
that
he
has
always
carried
on
the
business
of
farming
with
a
reasonable
expectation
of
profit.
The
appellant
had
a
full-time
job
as
a
bookkeeper.
In
addition
he
did
some
outside
bookkeeping
work
and
prepared
income
tax
returns
for
clients.
From
the
evidence,
it
was
apparent
that
his
farming
activities
had
virtually
come
to
a
stop
about
1966.
No
income
was
reported
in
1969
and
no
expenses
or
outlays
indicative
of
normal
farming
operations
were
reported.
Under
the
circumstances
the
only
conclusion
the
Board
can
draw
is
that
the
appellant
at
the
relevant
time
was
no
longer
in
the
business
of
farming
with
a
reasonable
expectation
of
profit.
I
also
find
on
the
basis
of
the
facts
adduced
that
the
appellant’s
earned
income
for
the
1969
taxation
year,
within
the
meaning
of
paragraph
79B(1)(c)
and
subsection
32(5)
of
the
Income
Tax
Act,
was
$4,331.37.
Appeal
dismissed.
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