Posocco v. R., [1998] 1 CTC 2877 -- text
Lamarre Proulx T.C.J.:
Lamarre Proulx T.C.J.:
Bowie T.C.J.:
Tardif T.C.J.:
This is an appeal from an assessment for the 1994 taxation year. The
facts can be very simply summarized; they are moreover admitted by both parties.
Lamarre Proulx T.C.J.:
The appellant appealed under the informal procedure from an assessment made by the Minister of National Revenue (the “Minister”) concerning deductions made at source but not remitted during 1992 and 1993.
Sarchuk T.C.J.:
Sarchuk T.C.J.:
Bell T.C.J.:
There are two issues in these appeals:
Bell T.C.J.:
The issue is whether the Appellant, in respect of his immigration consulting activities, had a reasonable expectation of profit in the 1991, 1992 and 1993 taxation years.
Watson D.J.T.C. .
This appeal was heard in Kitchener, Ontario on October 20, 1997.
Sobier T.C.J.: