Michel Sirois v. Minister of National Revenue, [1988] 1 CTC 2147, 88 DTC 1114 -- text
Couture, C.J.T.C. [Translation]:—These appeals concern assessments by the respondent for the 1981 and 1982 taxation years. Under these assessments the respondent disallowed the losses claimed by the appellant on the presumption that the restaurant business he had been