Rip T.C.J.:

O^Connor T.C.J.:

This appeal was heard at Yellowknife, Northwest Territories on August 4, 1998. The Appellant represented himself and he was the only witness.

The issue is whether the Appellant is entitled to an allowable business investment loss in the 1994 year pursuant to section 50 of the Income Tax Act (“Act’).

I find the principal facts to be as follows:

1. The Appellant was the principal owner of Turn-Air Ltd. (“Turn- Air”);

Bonner T . C.J.:

The Appellants appeal from assessments under section 160 of the Income Tax Act in respect of transfers of property in the form of dividends paid to them by Felm Investments Limited (“Felm”) as follows:

Garon T.C.J. .

Mogan T.C.J.:

Margeson T.C.J.:

Margeson T.C.J.:

This matter was set down for trial some time ago, for January 8, 1998, in Vancouver, B.C. By an Order of the Chief Judge dated December 11, 1997, an adjournment was granted. It was fixed peremptorily to be heard by this Court at this place at 9:30 a.m. on this date.

Tardif T.C.J.:

These appeals are from notices of reassessment for the 1990 and 1991 taxation years. The appellant, a CEGEP teacher, took courses at the same time that she was a teacher and obtained a master’s degree in 1983.

When she completed her new training, a number of friends and colleagues encouraged her to make her services and skills in relaxation and visualization available. She followed that advice.

Beaubier T.C.J.:

McArthur T.C.J.:

This appeal is from a reassessment made under the Income Tax Act for the Appellant’s 1990 taxation year. Essentially two issues are raised:

a) Was the Minister of National Revenue correct in adding the sum of $403,103.85 to the Appellant’s taxable income for the 1990 taxation year following a “net worth” assessment?

b) Was the Minister justified in assessing penalties under subsection 163(2) of the Income Tax Act?