Davidson Estate v. The Queen, 96 DTC 1652, [1996] 3 CTC 2900 (TCC) -- text
Bell J.T.C.C. : —
Issue
The issue in respect of the Appellant’s 1992 taxation year is whether each of
Bell J.T.C.C. : —
The issue in respect of the Appellant’s 1992 taxation year is whether each of
Taylor J.T.C.C.: — These are appeals heard in Toronto, Ontario, on August 2, 1996 against assessments for the years 1991, 1992 and 1993, in which the Respondent had disallowed rental losses claimed against other income, under the Income
Sobier J.T.C.C. (orally): — The Appellant in this proceeding filed his Notice of Appeal with the Court apparently on or about January 29th, 1996 because there is a document called “Notice of Appeal, informal procedure” signed by Mr. Zhuang
Sobier J.T.C.C.: — This appeal was heard under the Informal Procedure of this Court.
Bowman J.T.C.C.: — These appeals from assessments for 1988 and 1989 involve a question of the deductibility of $3,688.52 and $27,915.46 in interest on a loan of $300,000.00. In brief the appellant contends that the borrowed money was used to
Bowman J.T.C.C.: — These appeals are from assessments for the 1989, 1990 and 1991 taxation years. They involve the deductibility of losses sustained by the appellant in respect of a single family dwelling in Tucson, Arizona. The principal basis of
Bowman J.T.C.C.: — These appeals were heard together on common evidence. They relate to assessments made under the Income Tax Act for the taxation years 1990, 1991 and 1992 of both the individual appellant and his
Sobier J.T.C.C. (orally): — Thank you. I think I could give judgment from the Bench.
Beaubier J.T.C.C. (orally): — This matter was heard at Kelowna, British Columbia on March 28, 1996, pursuant to the Informal Procedure. The Appellant was the only witness.
Bowman J.T.C.C.: — This appeal is from an assessment for the appellant’s 1989 taxation year, and specifically for the taxation year comprising the fiscal period commencing on July 1, 1989 and ending December 31, 1989.