Howard Partington v. Minister of National Revenue, [1991] 1 CTC 2429 -- text
Lamarre Proulx, J.T.C.C.:—These appeals concern reassessments of tax for the years 1982, 1983, 1984 and 1985.
The questions in issue are the following:
(a) whether the appellant's breeding of dogs and operating of a kennel is a farming activity;
(b) whether the appellant's activity may be divided into two: the breeding of dogs which would be a farming activity and the operating of a kennel which would be a non-farming activity;