Michel Champagne v. Minister of National Revenue, [1993] 1 CTC 2655, 93 DTC 479 -- text
Tremblay, J.T.C.C:—This appeal was heard on April 7, 1992, in Sherbrooke, Quebec.
Tremblay, J.T.C.C:—This appeal was heard on April 7, 1992, in Sherbrooke, Quebec.
Hamlyn, T.C.C.J.:—The appellant purchased a residential unit (the''unit") and in January of 1988 sold the unit and made a profit of $47,292 (the ” profit"). The appellant's 1988 tax return (the "return") did not reflect the profit. In reassessing the appellant's return, the Minister of National Revenue (the"Minister") included the profit in the appellant's income. In addition, the Minister levied penalties (the " penalties”) under subsection 163(2) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act")..
Hamlyn, T.C.C J.:—The appeals in this matter were filed March 6, 1991.
Bonner, T.C.C.J. (orally):— Well, Mr. Katzenstein, I'm going to dismiss your wife's appeals. There are two taxation years involved, 1989 and 1990.
Garon, T.C.C.J. (orally):—These appeals are from assessments relating to the 1982, 1983 and 1984 taxation years. By these assessments, the Minister of National Revenue disallowed the deduction of the following amounts for the years indicated:
Lamarre Proulx, T.C.CJ.:— The appellant instituted an appeal from the assessment of respondent, the Minister of National Revenue (the"Minister"), for its 1986 taxation year.
Beaubier, T.C.C.J.:—These matters were heard in Victoria, British Columbia, on September 29, 1992 and on February 9 and 10, 1993, jointly and on common evidence by consent. No. 90-3890(IT) is an appeal under the old procedure of this Court. No.
Tremblay, T.C.C.J.:—These appeals were heard on common evidence in Montreal, Quebec, on February 6, 1992.
Lamarre Proulx, T.C.C.J.:—These are appeals from reassessments for 1980, 1981, 1982 and 1983. These reassessments were made by the respondent using the net worth method. This method is used by the Minister of National Revenue (the "Minister") where bad
Mogan, T.C.C.J.:—The principal business of the appellant is to provide a hot oil service for producing wells of major oil companies. The service is provided by transporting a hot oil unit to a particular well; operating the unit at the well for a number of