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?

Sarchuk T.C.J.:

This is an appeal by Gordon Collins (the Appellant) from an assessment of tax with respect to his 1992 taxation year. In computing his income for that year, the Appellant claimed $7,479.27 as a business investment loss. That amount was subsequently revised to $8,983.06 as set out in Schedule A to the Reply to the Notice of Appeal of the Minister of National Revenue.

Bonner T.C.J.:

McArthur T.C.J.: