Lamarre T.C.J.:

Beaubier T.C.J.:

1 These appeals pursuant to the Informal Procedure were heard at Edmonton, Alberta on June 6, 1997. The Appellant testified and the Respondent called Brent Aylesworth, Revenue Canada's appeals officer, in respect to this matter.

Bowie T.C.J.:

Bowie T.C.J.:

Bowman T.C.J.:

1 This is an appeal from an assessment for 1994 whereby the Minister of National Revenue refused to allow the appellant the disability tax credit provided by section 118.3 of the Income Tax Act

2 The issue is whether in that year Mr. Carmen had a severe and prolonged physical disability, the effects of which were to markedly restrict his ability to perform a basic activity of daily living.

Bowman T.C.J.:

Tardif T.C.J.:

Bell T.C.J.:

Issue:

• 1. Did the Appellant transfer money to his infant children within the meaning of subsection 75(1) of the Income Tax Act (“Act”) in prior years with the result that interest earned on that money would be attributed to the Appellant?

Rowe D.J.T.C.:

Dussault T.C.J.:

1 These appeals were heard under the informal procedure. They are appeals from assessments for the appellant's 1994 and 1995 taxation years.

2 In assessing the appellant, the Minister of National Revenue (“the Minister”) disallowed the credit for mental or physical impairment provided for in ss. 118.3 and 118.4 of the Income Tax Act (“the Act”).