Hamlyn T.C.J.:

THE REGISTRAR: Order. Please rise. Court is resumed. Please be seated.

HIS HONOUR: This is in the matter of Joan Tingley and Her Majesty the Queen. It’s an appeal for the 1993, 1994, and 1995 taxation years.

At all relevant times, the appellant was resident in Canada, and the appellant received pension income from United Steel Workers of America, a source in the United States, for the 1993, 1994, and 1995 taxation years.

Lamarre T.C.J.:

These are appeals under the informal procedure from assessments made by the Minister of National Revenue (“Minister”) under the Income Tax Act (“Act”) for the appellant’s 1986, 1987, 1988 and 1989 taxation years. In so assessing the appellant, the Minister disallowed capital cost allowance on rental properties (class 3 assets) for each of the taxation years at issue, the amounts involved being $23,042, $17,907, $12,962 and $10,460 respectively. The Minister relied on the following assumptions of fact:

Lamarre Proulx T.C.J.:

These are appeals for the years 1986, 1987 and 1988. The Appellant was reassessed for these years for unreported income in the approximate amounts of $10,000, $40,000 and $100,000 respectively. Penalties were also assessed pursuant to subsection 163(2) of the Income Tax Act (the “Act’).

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

These appeals are governed by the informal procedure provided for under section 18 and following sections of the Tax Court of Canada Act. The years under appeal are 1992, 1993, 1994. The appellants are husband and wife and the appeals were heard together.

The Notice of Appeal filed by Jason Leung reads:

Bowman T.C.J.:

These appeals are from assessments for 1991, 1992, 1993, 1994 and 1995.

There are two issues:

(a) the deductibility of legal expenses incurred by the appellant in 1993, 1994 and 1995;

(b) the deductibility of certain business expenses claimed by the appellant in 1991 and 1992.

The appellant in the years in question was a self-employed associate with Financial Concept Group.

Margeson T . C.]. :

This matter for decision is the case of Hans Zahn, 89-2827(IT). The issue is with respect to a business loss in the 1984 and 1985 taxation years.

In evidence given before the Court, the Appellant indicated that he started entertaining in 1976. He had a “full-time show” and made a living from it. It was underwritten by corporate sponsors. Due to the fact that the population is very small the possibility of making a profit was limited.

Bonner T.C.J.:

This is an appeal from assessments of income tax for the 1986 and 1988 taxation years. On assessment the Minister of National Revenue included in the Appellant’s income amounts calculated under section 94.1 of the Income Tax Act in respect of “offshore investment fund property” held by the Appellant.

Bowie T.C.)J.:

By agreement of the parties, the appeals of these 15 Appellants were heard together on common evidence. The appeals are from assessments for income tax for the years 1986, 1987, 1988 and 1989.!.[1] The description of the facts which follows is as they existed during the years under appeal. Some of these facts have changed since 1989, but to the extent that they have, it is not relevant to the disposition of the appeals.

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

This appeal is governed by the Informal Procedure prescribed under section 18 and following sections of the Tax Court of Canada Act. The year under review is 1994.

The Notice of Appeal reads:

I wish to appeal a Notice of Reassessment originally dated February 2, 1996 and subsequently varied with a letter dated August 5, 1997 for the 1994 taxation year under the Informal Procedures.

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

This appeal is governed by the Informal Procedure prescribed under section 18 and following sections of the Tax Court of Canada Act. The year under review is 1995.

The Notice of Appeal reads:

The Relevant Facts and Reasons for Appealing: (L502/R1970/T2/BT2) test_linespace (240>217.60) 0.839 0250_3467_3607