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
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 issue is whether in computing her income for 1995 the appellant is entitled to a tuition credit in the amount specified in paragraph 1 18.5(1)(a) of the Income Tax Act (“the Act’). That portion of paragraph 118.5( 1)(a) which is relevant to this appeal provides:
Teskey T.C.J.:
The Appellant appeals its reassessment of income tax for its 1985 taxation year.
The sole issue is the deductibility of interest payments from income which payments were paid on a loan from the Bank of Nova Scotia.
