Brault-Clement Inc. v. The Queen, 86 DTC 6277, [1986] 2 CTC 1 (FCTD), aff'd 92 DTC 6010 (FCA) -- text
Le juge Pinard:—Il s’agit d’un appel, sous forme d'action, en vertu du paragraphe 172(2) de la Loi de l'impôt sur le revenu, Statuts de 1970-71-72,
Le juge Pinard:—Il s’agit d’un appel, sous forme d'action, en vertu du paragraphe 172(2) de la Loi de l'impôt sur le revenu, Statuts de 1970-71-72,
Christie, A.C.J.T.C.:—On July 25, 1975 the respondent reassessed the appellant in respect of his 1973 taxation year. The reply to notice of appeal is dated July 9, 1979. Paragraph 2 and 3(a) are under the heading Statement of Facts. They read:
Brulé, T.C.J.: —The present appeal, dealt with by written submissions, is from the Minister's assesment for the 1982 taxation year by which he disallowed the appellant's claim for moving expenses in the amount of $6,780.97.
Brulé, T.CJ.:—These appeals, which were heard on common evidence, with respect to certain years, concern the deductibility of the capital cost of property described in Class 12 of Schedule "B" of the Income Tax Regulations as a “certified feature production".
Taylor, T.C.J.:—This is an appeal against an income tax assessment, for the year 1981, heard on February 3, 1987, in Toronto, Ontario, in which the Minister of National Revenue disallowed amounts of $144,000 and $1,285 claimed as expenses against income.
Brulé, T.C.J.:—This is an appeal from reassessments relating to the appellant's 1980, 1981 and 1982 taxation years in which the respondent added amounts to income in 1980 of $24,800, in 1981 of $25,688, and by disallowing a deduction in 1982 of