McArthur T.C.J.:

1 This appeal, under the informal procedures, concerns the Appellant's 1992 taxation year.

2 The issue is whether the Appellant is liable for a late filing penalty of $80.27 and interest which amounted to $110.45.

Tremblay T.C.J.:

1 This appeal was heard at Trois-Rivières, Quebec under the informal procedure on April 7, 1997.

Bell T.C.J.:

1 The evidence in the case of Robert W. Billingsley (“Billingsley”) applies in this case.

Issues

• 1. Whether the Appellant should have a taxable capital gain included in its income for its 1987 taxation year,

Lamarre Proulx T.C.J.:

1 This is an appeal by way of the informal procedure; it concerns the disability tax credit provided for by section 118.3 of the Income Tax Act (the “Act”) which was claimed by the Appellant for the 1995 taxation year.

Taylor T.C.J.:

1 This is an appeal heard in London, Ontario, on June 12, 1997, against assessments under the Income Tax Act (the “Act”) for the 1992 and 1993 taxation years in which the Respondent disallowed amounts of $28,474.08 and $31,693.84 respectively claimed as “business losses”, by reducing such losses to $1 for 1992 and $2,698 for 1993.

McArthur T.C.J.:

1 These appeals are from reassessments for the Appellant's 1987, 1988, 1989, 1990 and 1991 taxation years. They involve the disallowance by the Minister of National Revenue (the “Minister”) of expenses incurred by the Appellant from a consulting business the Appellant avows he conducts.

O'Connor T.C.J.:

1 The Minister of National Revenue (“Minister”) denied deductions claimed by the Appellant for legal fees of $13,845.78 in 1994 and $31,170.19 in 1995 and the issue is whether the Minister was correct in so doing.

2 The basic facts are as follows. Prior to February 1991 the Appellant was a licensed real estate agent in the employ of Homelife Solaris Realty Inc. (“Homelife”).

Beaubier T.C.J.:

1 This appeal pursuant to the General Procedure was heard at Prince George, British Columbia on April 30, 1997. The Appellant and his brother Rick testified.

2 The issue is whether the Appellant's purchase and sale of a 210 acre parcel of land, legal description DL 12499, in 1988 was on account of income or capital.

Taylor T.C.J.:

Watson D.J.T.C.: