Jérémie Dauphinais v. Her Majesty the Queen, [1994] 1 CTC 2288 -- text
Garon, J.T.C.C.:—This is an appeal from a reassessment of the Minister of National Revenue issued on April 17, 1990 for the 1982 taxation year.
Garon, J.T.C.C.:—This is an appeal from a reassessment of the Minister of National Revenue issued on April 17, 1990 for the 1982 taxation year.
Tremblay, J.T.C.C.:—This appeal was heard on June 16, 1993, in Montreal, Quebec.
Rip, J.T.C.C. (orally):—Mr. Papp.
MR. PAPP: Yes, Your Honour.
Garon, J.T.C.C.:—These are appeals by the eight appellants from income tax assessments dated January 10, 1989 made by the Minister of National Revenue (the ''Minister") for the 1986 taxation year. In those assessments, the Minister determined that the $813,250 gain realized by the appellants[1] in the sale on June 3, 1986 of the Place Charlevoix shopping centre located at 1000 Boulevard de Comporté, city of La Malbaie, Quebec, constituted business income.
Tremblay, J.T.C.C.:— This appeal was heard according to the informal procedure, on June 14, 1993, at Montréal, Quebec.
Mogan, J.T.C.C. (orally):— This is an appeal commenced under the provisions of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") in respect of the appellant's 1987 taxation year. From 1972 to
Brulé, J.T.C.C.:—The appellant has instituted an appeal from the determination of the Minister of National Revenue ("Minister") of November 8, 1990 confirming the notice of assessment of January 24, 1990, which reads as follows:
Mogan, J.T.C.C.:— In 1978, the appellant was diagnosed with multiple sclerosis (MS), a neurological disease. In 1989 and 1990, she deducted a tax credit under section 118.3 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c.
Lamarre Proulx, J.T.C.C.:— These two appeals were heard on common evidence. The taxation years in issue are 1982, 1983, 1984 and 1985.
Garon, J.T.C.C.:—This is an appeal under the informal procedure from an assessment of the Minister of National Revenue dated August 9, 1991 for the appellant’s 1988 taxation year. By that assessment the Minister of National Revenue included in the appellant’s income $75,000 received from Métro- Richelieu Inc. ("Métro"), whereas the appellant had considered that the amount was the proceeds of disposition of eligible capital property and as such had included the sum of $36,560 in its income.