D E Taylor:—This is an appeal heard in Toronto, Ontario, on September 24, 1981 against income tax assessments for the years 1973, 1974 and 1975 In which the Minister of National Revenue added amounts of $11,858, $89,384 and $89,485 respectively
John B Goetz:—This is an appeal with respect to the appellant’s 1976, 1977 and 1978 taxation years, wherein the appellant claimed as farming losses the amounts of $7,762.41, $4,036.51 and $7,848.70 respectively. An adjustment for interest for the said
The Chairman:—The appeal of Maxine Ann McNeely is from an assessment in respect of the 1977 taxation year.
The facts of this appeal are not in dispute and can be summarized as follows:
The Chairman:—The appeal of Johannes Braaksma is from an assessment in respect of the 1977 taxation year.
M J Bonner:—The assessments under appeal are based on a direction made by the respondent under subsection 247(2) of the Income Tax Act that the following corporations be deemed to be associated with each other for the
The Chairman:—The appeal of Scandia Plate Ltd is from an assessment whereby the Minister of National Revenue disallowed a small business deduction under subsection 125(1) of the Income Tax Act on the ground that the appellant was
M J Bonner:—This is an appeal from an assessment of income tax for the 1978 taxation year. On assessment the respondent included in income certain service contract revenue received during the year. The appellant, in its domestic financial statements,
M J Bonner:—This is an appeal from an assessment of income tax for the appellant’s 1978 taxation year. The events giving rise to the assessment are somewhat unusual. The appellant had borrowed money from its bank, the Bank of Montreal. On
M J Bonner:—This is an appeal from an assessment of income tax for the appellant’s 1977 taxation year ending July 31, 1977. The appellant at all relevant times carried on the business of a franchisor of take-out chicken stores. In the
The Chairman:—The appeal of Ernest Bouchard is from an assessement with respect to the 1976 and 1977 taxation years.
There are two separate issues arising from the Minister’s assessment:
