Christie, ACJTC:—This appeal is against a reassessment by the respondent under the Income Tax Act ("the Act") regarding the appellant’s 1977 taxation year. In reassessing, the respondent disallowed a claimed deduction by the appellant for

Couture, CJTC [ORALLY]:—After having heard the evidence of Mr Connell and having regard to the present jurisprudence in the decisions of the Federal Court of Appeal in The Queen v Paul E Graham and of the Federal

Taylor, TCJ :—This is an appeal heard in Toronto, Ontario, on September 23, 1985, against an income tax assessment, in which the Minister of National Revenue imposed a late filing penalty of $9,705 under subsection 162(1) of the Income

Rip, TCJ:—The facts in Mr Steven Adam's appeal from an income tax assessment for 1982 are not in question. The issue is whether a salary, once paid as salary, can be made retroactively into a dividend.

Bonner, TCJ [ORALLY]:—This is an appeal from an assessment of income tax for the appellant’s 1983 taxation year. At issue is the deductibility of $1,299 which is the total of amounts claimed as promotion, long distance telephone and parking charges.

Brulé, TCJ [ORALLY]:—What is before the Court today is a motion by the taxpayer concerning his 1979, 1980 and 1981 taxation years. The motion stems from assessments which included by the Minister the application of subsection 74(5) of the Income

Taylor, TC|:—This is an appeal heard in Toronto, Ontario, on September 24, 1985, against an income tax assessment for the year 1980, in which the Minister of National Revenue disallowed, as a deduction against her investment income, an amount of $230

Sarchuk, TCJ:—The appeals of Gladys Balsillie are in respect of her 1973, 1974 and 1975 taxation years. The respondent’s reassessments were based on the following facts and assumptions:

Tremblay, TCJ [TRANSLATION]: This case was heard at Montreal, on August 30, 1984.

Bonner, TCJ:—This is an appeal from an assessment of income tax for the 1982 taxation year. The facts are not in dispute. The appellant was employed by Markborough Properties Limited from 1978 to the end of February 1982. The appellant was then