Teskey T.C.J.:
The Appellant in his Notice of Appeal herein, appealed his reassessment of income tax for the year 1994 and elected the Informal Procedure.
The three issues herein are:
(a) whether the Appellant is entitled to a non-refundable tax credit for mental or physical impairment pursuant to subsection 118.3(1) of the Income Tax Act (the “Act”), in the computation of his tax payable for the 1994 taxation year;
Archambault T.C.J.:
Lamarre T.C.J.:
The appellant is appealing from an assessment dated June 12, 1996 in the amount of $9,215.85, which was made pursuant to section 227.1 of the Income Tax Act (the "Ac").
The appellant is a lawyer by profession and has had a general commercial and estate law practice in Edmonton for 46 years. As such, he has sat on the boards of many corporations.
Teskey T.C.J. (orally):
HIS HONOUR: The Appellant appeals an assessment of income tax for the years 1991, 1992 and 1993. In his Notice of Appeal he elected the Informal Procedure.
Teskey T.C.J.:
The Appellant in her Notice of Appeal wherein she appealed her assessment of income tax for the years 1993 and 1994, elected the informal procedure.
The sole issue before me is whether the sum of $20,812 and $54,018 received in 1993 and 1994, respectively, was on capital account or income account.
The Appellant, a 55 year old married woman, the mother of seven children, describes herself as a sales representative.
Lamarre Proulx T.C.J.:
This is an appeal from an assessment made by the Minister of National Revenue (“the Minister”) pursuant to s. 160 of the Income Tax Act (“the Act”).
Tremblay T.C.J.:
According to the Notice of Appeal and the Reply to the Notice of Appeal the question is whether, in calculating his income for the 1986 taxation year, the appellant is entitled to deduct $3,191 as fees paid to investment counsel pursuant to s. 20(1)(bb) of the Income Tax Act (“the Act”).
Lamarre Proulx T.C.J.:
The Appellant is appealing the reassessments of income tax made by the Minister of National Revenue (the “Minister”) for the taxation years 1991 to 1994.
Bowie T.C.J.:
Beaubier T.C.J. (orally):
His Honour: And the Appellant is present in person. Put that on the record, please. This appeal pursuant to the Informal Procedure was heard at Saskatoon, Saskatchewan on June 29 and 30, 1998. The Appellant testified. The Respondent called three employees of Revenue Canada: Barry McKenzie, Sheila Nixon and Gilbert Hertlein.
Paragraphs 7 to 10 inclusive of the Reply to the Notice of Appeal read:
