M J Bonner:—Tony Mele Incorporated (the “company”) appeals from an assessment of income tax for its 1980 taxation year. Tony Mele appeals from assessments for his 1978, 1979 and 1980 taxation years. The appeals were heard together on common evidence.

Taylor, TCJ:—This is an appeal heard in Toronto, Ontario on September 18, 1984 against an income tax assessment for the year 1979 in which the Minister of National Revenue allowed only the “restricted farm loss” to the appellant, whereas the appellant