Avrum Schwam Holdings Inc. v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2728 -- text
Archambault, J.T.C.C.:— These are income tax appeals for the 1987 and 1988 taxation years heard under the informal procedure in Montréal. The Minister of National Revenue (the "Minister") has disallowed farming losses of $24,888 for the 1987 taxation year and $31,159 for the 1988 taxation year pursuant to section 31 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"). Counsel for the respondent conceded that there was no issue whether the appellant was carrying on a farming business.