Archambault J.T.C.C.:-Mr, David McMillan faced a difficult problem in 1990. Separated from his wife, he had to pay a maintenance allowance to his wife for the benefit of his two children. Because his personal income fluctuated, he could not commit to a
O’Connor J.T.C.C.:-This appeal was heard in Edmonton, Alberta on October 4, 1994 pursuant to the informal procedure of this Court.
McArthur J.T.C.C.:-Appellants Barry J. McHugh and Barbara L. McHugh have appealed their income tax assessments for the 1981, 1982, 1983 and 1984 taxation years. Inland Development Company Ltd. ("IDCL") has appealed its income tax assessments for the same years as well as for the 1985 and 1986 taxation years. McHugh Minerals Ltd. ("MML") has appealed from reassessments of its 1982, 1983 and 1984 taxation years. The appeals were heard on common evidence upon consent.
Brulé J.T.C.C.:—The appellant appeals the reassessments in connection with his 1985, 1986, 1988 and 1989 taxation years.
Rip J.T .C.C.:-Robert Kondrat has appealed his notice of reassessment for 1985 claiming that (a) $73,500 paid by Karon Resources Inc. ("Karon”), a company of which he was the sole shareholder at the time, to Linda Kondrat, his spouse at the time,
Brulé J.T.C.C.:-This is an application for an order extending the time within which an appeal may be instituted from the reassessments by the Minister of National Revenue of his income tax returns for the years 1986, 1988 and 1989.
Bowman J.T.C.C.:-The central issue in all of these appeals which were heard together is the fair market value at December 31, 1971 (valuation day, or V-day) of a number of parcels of land owned by the appellants in Delta, British Columbia at or near to the intersection of Highway 17 and 60th Avenue. Other issues arise but they are for the most part subsidiary to that central issue.
Margeson J.T.C.C.:-In the taxation years 1991, 1992 and 1993, the appellant sought to deduct the amounts of $5,865.42, $6,275 and $7,294.23, respectively as business development and client entertainment expenses. The appellant was a member of a partnership engaged
Bowman J.T.C.C. (orally):—I shall now render judgment in the case of Dr. Phela Goodstein, court file number 94-54.
These appeals are from reassessments for the appellant’s 1987, 1988, and 1989 taxation years.
Margeson J.T.C.C.:-The sole question before me for determination is whether the amount in question, $21,029.66 received in the year 1991, is to be included in income in that year. There was withholding tax deducted from the gross amount in accordance
