Bell T.C.J.:
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”).
Bell T.C.J.:
1 The issue in this appeal is whether the Appellant is liable, under subsection 227.1(1) of the Income Tax Act (“Act”), in respect of amounts which Old Country Public Houses Ltd. (“Old Country”) failed to deduct and remit to the Receiver General of Canada.
2 The Appellant was, according to her counsel, unable, because of illness, to attend at Court. Evidence was given on her behalf by her husband, John Lewis Murray (“Murray”).
Hamlyn T.C.J. (orally):
1 This is in the matter of Todd Zator and Her Majesty The Queen and it is an appeal with respect to the 1991 and 1992 taxation years. In computing his income for the 1991 and 1992 taxation years. Mr. Zator claimed rental losses in the amount of $7.183.60 and $10,061.89. In reassessing Mr. Zator for the 1991 and 1992 taxation years, the Minister of National Revenue disallowed the deduction of the rental losses.
Lamarre Proulx T.C.J.:
1 These are appeals from reassessments by the Minister of National Revenue (the “Minister”) for the 1992 and 1993 taxation years.
2 The point for determination is whether the appellant may deduct business losses of $9,930 for 1992 and $7,431 for 1993 in computing his income for those years.
Hamlyn T.C.J.:
1 This appeal is with respect to the Appellant's 1988 and 1989 taxation years. The Appellant, a publicly traded company, has formerly been known by such names as Portcomm Communications Corporation Limited (“Portcomm”), Hal Roach Studios Corp., and HRS Industries Inc.
McArthur T.C.J.:
1 In assessments for the 1990 and 1991 taxation years of Anita Franklin, the Appellant, was disallowed deductions for losses in the amounts of $41,379.00 and $66,855.00, respectively, which assessments she is appealing.
Rowe T.C.J. (Orally):
1 HIS HONOUR: The appellant appeals with respect to an assessment of income tax for the 1994 taxation year. In that particular year, in computing income, the appellant deducted the amount of $8,345.00 as a business loss, and claimed a rental loss in the sum of $10,147.00.
2 The deduction of the business loss arose from a claim relating to the appellant's investment in a purported business connected with a band known as “Big Medicine”.
Beaubier T.C.J.:
1 This appeal pursuant to the Informal Procedure was heard at Regina, Saskatchewan on February 16, 1998. The Appellant and Raymond Harding testified for the Appellant. The Respondent called an appraiser of farm property, John Grey to testify.
