The Chairman:— This is the appeal of Mr Tarsem L Kapal from an income tax assessment in respect of the 1975 taxation year. In his tax return, the appellant claimed an amount of $3,158 as payment for dependants in India, particularly his

Guy Tremblay:— This case was heard in Vancouver, British Columbia, on February 21, 1979, on common evidence with the cases of Mei Yang Wong (78-850), and Jorge Hien-Lang Tseng (78-851).

1. Point at Issue

The point is whether the appellant is correct in deducting the amount of $1,336.72 of tax payable on his return for the 1976 taxation year. This amount of $1,336.72 was tax paid to the government of Hong Kong for rental income, pursuant to the Inland Revenue Ordinance of Hong Kong.

Guy Tremblay:— This case was heard in Vancouver, BC on February 21 and 22, 1979.

The Assistant Chairman:—When CFTO TV Limited (hereinafter called the “appellant”) filed its income tax return for each of its fiscal years 1971, 1972, 1973 and 1974, on the statement entitled “Reconciliation of Net Income per Financial Statements with

Guy Tremblay:—This case was heard in Ottawa, Ontario, on December 6, 1978, on common evidence with the case of George W Martin (File No 77-346).

M J Bonner:—I will now give my decision. This is an appeal from assessments of income tax for the 1972 to 1975 taxation years, both inclusive.

Delmer E Taylor:—This is an appeal heard in the City of Vancouver, British Columbia, on December 3, 1979, against an income tax assessment in which the Minister of National Revenue disallowed the $1,000 pension deduction claimed by the appellant for

Guy Tremblay [TRANSLATION]:—This case was heard at Quebec City, Quebec on October 19, 1979.

Delmer E Taylor:—This is an appeal against several items in income tax assessments for the years 1974 and 1975. It was heard in the City of London, Ontario, on November 8, 1979. At the commencement of the hearing, counsel for the

Guy Tremblay:—This case was heard in Vancouver, BC on February 20, 1979. Following the written submissions, this case was taken under advisement on April 27, 1979.