Christie A.C.J.T.C.:

Margeson T.C.J.:

By Notices of Reassessment dated August 10, 1993 and August 11, 1995, the Minister of National Revenue (the “Minister”) reassessed the Appellant for the 1986 to 1991 taxation years, inclusively, for tax and imposed penalties and interest.

Bowman T.C.J.:

These appeals are from assessments for the 1992, 1993 and 1994 taxation years made against the late Mr. Hausmann whereby the Minister of National Revenue included in his income a pension received from the Government of Belgium in the amounts of $4,800, $4,761 and $5,217 respectively. It appears the amounts were received in Belgian francs. The assessments were based upon clause 56( 1 )(a)(i)(C. 1 ) of the Income Tax Act which reads:

O^Connor T.C.J.:

These appeals were heard at Toronto, Ontario on April 9, 1998 pursuant to the Informal Procedure of this Court. The Appellant was the only person to give evidence.

Issue

The issue is whether the Appellant was entitled in the years 1991 through 1994 to deduct certain rental losses with respect to her home in Oshawa, Ontario.

Facts

I find the basic facts to be as follows.

Mogan T.C.J.:

When computing income for her 1995 taxation year, the Appellant deducted certain child care expenses under subsection 63(1) of the Income Tax Act. Upon reassessment, her deduction was disallowed because she did not have receipts from the person who provided the child care. The Appellant has appealed from the disallowance of her deduction and I am required to apply subsection 63(1) to the facts of this case.

Archambault T.C.J.:

Mr. George Desnomie is appealing a reassessment issued by the Minister of National Revenue (Minister) with respect to the 1989 taxation year. Mr. Desnomie, an Indian within the meaning of the Indian Act, R.S.C. 1985, c. 1-5, claimed an exemption pursuant to paragraph 81(1)(a) of the Income Tax Act (Act) and pursuant to sections 87 and 90 of the Indian Act.

Sarchuk T.C.J.:

These are the appeals of John G. Caraberis and Bonnie Bond (the Appellants) from assessments of tax with respect to their 1989, 1990, 1991 and 1992 taxation years. By agreement of all parties, the appeals were heard together on common evidence. Four separate issues were raised and with respect thereto, the parties filed an agreed statement of facts. Further testimony was adduced on behalf of the Appellants from Caraberis, Stephen

Rowe D.J.T.C.:

The appellant appeals from an assessment of income tax for her 1993 taxation year (97-676(IT)l) and also from assessments of income tax for her 1994 and 1995 taxation years (97-2974(IT)I). The appellant and counsel for the respondent agreed her appeals would be heard together and all parties agreed the appeal of Robert V. Burns (97-675(IT)l) from an assessment of income tax for his 1992 taxation year would be heard at the same time on common evidence.

McArthur T.C.J.:

These appeals concerning the Appellants’ assessments, dated July 19, 1995, were heard on common evidence. The Minister of National Revenue (the “Minister”) assessed the Appellants $74,723[1] in respect of a Transfer of Property to them by their father, Michael B. Biderman, within the meaning of section 160 of the Income Tax Act (the “Act”). It is not in dispute that at all material times Michael B. Biderman was indebted to Revenue Canada and had been since 1989.

Beaubier T.C.J.:

This appeal pursuant to the Informal Procedure was heard at Cranbrook, British Columbia on June 9, 1998. The Appellant was called to give testimony by counsel for the Queen. George William Barker was called to give testimony by Marlene Barker’s agent. Mr. Barker was joined into the appeal of Marlene Barker by an Order under section 174 of the Income Tax Act.

Paragraphs 6 and 7 of the Reply to the Notice of Appeal read: