Mogan, T.CJ.:— The issue in this case is a question of law construing paragraph 110(i)(a) and subsections (1.2) and (2.1) of section 110 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") as those
Christie, A.CJ.T.C.:— This appeal relates to reassessments of the appellant's liability to tax under the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") regarding its 1984 and 1985 taxation years. The
Beaubier, T.C.J.:—These matters were heard on common evidence at the City of Calgary, Alberta, on July 11, 1991.
The only witness was Raymond Learsy, the president of Agricultural and Industrial Corporation. He and trusts of his family are the sole owners of that corporation.
Lamarre Proulx T.C.J. [Orally]:—The appellant is appealing from assessments by the respondent, the Minister of National Revenue, for the years 1982 and 1983.
Bowman, T.CJ.: —This is an application made on behalf of the respondent, Her Majesty the Queen, for an order dismissing the appellant's appeal for lack of jurisdiction.
Christie, A.CJ.T.C.: —In computing his income for 1988 the appellant sought to deduct a business loss of $58,142 in respect of a trading account with Wood Gundy, stock and bond brokers. This account was in the name of his late wife
Sobier, T.CJ.:—The appellant Dr. Dennis M. Karpiak ("Dr. Karpiak") appeals from the assessment of the respondent for his 1984, 1985, 1986, 1987 and 1988 taxation years, whereby the respondent:
Tremblay, T.C.J.: —These appeals were heard on common evidence at Montreal, Quebec, on May 31 and September 26, 1989.
Teskey, T.CJ.:—The appellant appeals from its reassessment in respect of its 1986 and 1987 taxation years wherein the Minister of National Revenue disallowed the appellant's claim that:
Kempo, T.C.J. [Orally]: —I am delivering these reasons for judgment orally, however I expressly reserve the right to edit and expand upon them subsequently if need be.
