Michel Pelchat v. Minister of National Revenue, [1984] CTC 2964 -- text
Tremblay, TCJ [TRANSLATION]:—This case was heard on September 28, 1983 in Quebec City, Quebec.
Tremblay, TCJ [TRANSLATION]:—This case was heard on September 28, 1983 in Quebec City, Quebec.
Cardin, TCJ [TRANSLATION]:—This is an appeal by Mr Robert Delisle against tax assessments for the 1977 and 1978 taxation years. It concerns the deductibility of certain amounts as expenses incurred in gaining income from a business.
St-Onge, TCJ [TRANSLATION]:—The appeal of Mr Claude Théoret was heard in Montréal, Quebec on April 4, 1984.
Cardin, TCJ [TRANSLATION]:—Since the respondent’s assessments were based on the same assumptions of fact, the appeals of Diane Charron-Brazeau and Huguette Lemieux-Brazeau were heard on common evidence.
Tremblay, TCJ [TRANSLATION]:—This case was heard at Montreal, Quebec on June 30, 1983.
Sarchuk, TCJ:—These appeals were by consent tried together on common evidence. The issue is not complex. The appellants operated a turf farm as a partnership. In the 1978 and 1979 taxation years wages claimed as expenses in the amount of $10,800
Bonner, TCJ [ORALLY]:—I will deal first with the claim of Mr Mihajlovic to deduct the expenses listed in paragraphs 4(c) and (e) of the reply to notice of appeal. I find the evidence far too vague to be persuasive. No vouchers were produced.
St-Onge, TCJ [TRANSLATION OF ORAL JUDGMENT]:—The appeal of Mr Irving Kott was heard in the city of Montréal, Quebec on April 3, 1984.
Kempo, TCJ:—
Part I Issue
Goetz, TCJ:—This is an appeal with respect to the appellant’s 1977, 1978 and 1979 taxation years whereby, as a result of a reassessment, the sum of $240,000 was added to the appellant’s income for his 1977 taxation year which, due to the