Sarchuk, TCJ:—This is the appeal of N M Tilley Realty Ltd from income tax assessments in respect of its 1978 and 1979 taxation years. The appellant owned 33% per cent of the issued shares of Paramount Manufactured Homes Ltd (Paramount)

Christie, CJTC [ORALLY]:—Windfalls are exempt from inclusion in computing income. In the world of Canadian taxation, the most famous windfalls of all are the proceeds of winning a prize under a lottery scheme. These prizes are not regarded as taxable

Tremblay, TCJ:—This case was heard on May 27, 1983, at the City of Ottawa, Ontario.

Tremblay, TCJ:—This case was called for hearing in London, Ontario on May 30, 1983 and written arguments were subsequently filed. The last submission was received by the Court on June 24, 1983, and the case was then taken under advisement.

Tremblay, TCJ:—These cases were heard on common evidence on June 6, 1983 in London, Ontario.

Goetz, TCJ [ORALLY]:—This is an appeal by the appellant with respect to his 1979 taxation year. The issue really resolves itself as to whether subsection 15(1) or subsection 15(2) of the Income Tax Act, SC 1970-72, c 63, as

Christie, CJTC:—This appeal pertains to the appellant’s 1977 taxation year. There are two issues. First, whether the appellant was entitled to deduct $4,620 from his total income as a bad debt, and, second, whether during the relevant period Whitby Dominion Hardware

Rip, TCJ:—These are appeals from assessments dated October 14, 1981, November 15, 1981, January 26, 1983 and March 30, 1983 in which the respondent, the Minister of National Revenue, assessed the appellant, Electrocan Systems Ltd (“Electrocan”), penalties pursuant

Cardin, TCJ:—The appeals of Dr Abram Friesen are from assessments of tax with respect to the 1976, 1977 and 1978 taxation years. The issue for 1976 is the amount of capital gain realized from the disposition of a parcel of land owned by

Goetz, TCJ:—[ORALLY] This is an appeal by the appellant with respect to her 1980 taxation year. The appellant was employed as a systems’ analyst in 1980 and had a remuneration from this position in the sum of $29,773.92 from which amounts were deducted pursuant