Aylward v. R., [1998] 1 CTC 2659 -- text
McArthur T.C.J.:
McArthur T.C.J.:
Christie A.C.J.T.C.:
This appeal is governed by the informal procedure provided for under section 18 and following sections of the Tax Court of Canada Act. The year under review is 1992.
Bowie T.C.J.:
Beaubier T.C.J.:
Sarchuk T.C.J.:
O’Connor T.C.J.:
McArthur T.C.J.:
Judge Mogan of this Court heard the evidence of the case under appeal and put the following on record:
Hamlyn T.C.J.:
Margeson T.C.J.:
Both Appellants appealed to this Court from an assessment made by the Minister of National Revenue, (the Minister), notices of which were dated July 7, 1995, for the 1992 taxation year.
Bell T.C.J.:
All statutory references, unless otherwise specified, relate to the Income Tax Act (“Act”).
The issues are:
1 Whether two dividends, namely,