Guy Tremblay:—

Roland St-Onge:—The appeal of Howden Brothers Construction Ltd came before me on October 10, 1979, at the City of Saskatoon, Saskatchewan.

Roland St-Onge:—The appeals of Mr John Flood and Mr Norman E Greenaway came before me on October 12, 1979, at the City of Saskatoon, Saskatchewan and were heard on common evidence.

Delmer E Taylor [TRANSLATION]:—This decision is being rendered following an application to the Tax Review Board for an extension of the time for appealing a tax assessment. The taxpayer is a chartered accountant and his ‘‘application for an extension

Delmer E Taylor [TRANSLATION]:—This appeal, which was heard in the City of Montreal, Quebec on October 9, 1979, was brought following tax assessments in which the Minister of National Revenue disallowed certain deductions the taxpayer had claimed for

M J Bonner:—This is an appeal from an assessment of income tax for the appellant’s 1975 taxation year. In her return of income for the year the appellant sought to deduct the sum of $33,333.34 as a business loss. The deduction was

M J Bonner:—The appellant appeals from assessments of income tax for the 1974 and 1975 taxation years. The respondent, in assessing, denied reserves claimed by the appellant under subsection 64(1) of the Income Tax Act.

Roland St-Onge:—The appeal of Mr Sam Kligman came before me on November 5, 1979, at the City of Montreal, Quebec. The issue is whether an amount of $8,754 received in 1972 is the appellant’s income even if it was received by a company

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.