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.:

Campbell J.:

1 The primary issue in this case is limited to whether Mr. Fegol can take advantage of a “farm equipment” exemption to obtain relief from a seizure which took place on July 15, 1994 for the purpose of offsetting an outstanding tax debt. Mr. Fegol was unrepresented at the trial and the respondent was represented by counsel, Mr. Fraser. Both did a capable job.

Hamlyn T.C.J.:

1 These are appeals for the 1988, 1989 and 1990 taxation years.

2 In computing income for the 1988, 1989 and 1990 taxation years, the Appellant deducted business losses in the amounts of $2,327, $12,460 and $12,431 respectively and deducted professional losses in the amounts of $4,951, $7,014 and $3,189 respectively.

Décary J.A.:

1 This is yet another “reasonable expectation of profit” case, involving what the Tax Court Judge described as:

[...] a unique situation where entrepreneurial parents with substantial means seek to establish a business in the context of their daughter learning how to ride and jump horses leading to the highest of the world's competitive levels.

Lamarre T.C.J.:

1 This is an appeal under the informal procedure from an assessment issued by the Minister of National Revenue (“Minister”) against the appellant for the 1994 taxation year denying her the non-refundable tax credit for a dependant having an impairment under subsection 118.3(2) of the Income Tax Act (“Act”).

Watson D.J.T.C.:

1 This appeal was heard under the Informal Procedure in London, Ontario, on May 5, 1997.

2 In computing income for the 1993 taxation year, the Appellant deducted the amount of $2,816.94 as other employment expenses. In reassessing the Appellant for this taxation year, the Minister of National Revenue (the “Minister”) reduced the deduction of the expenses in the year to $1,157.97.

Rip T.C.J.:

1 Egbert Andrew Williams has appealed assessments made under the Income Tax Act (“Act”) for the 1991 and 1992 taxation years on the basis that he be permitted to deduct expenses incurred in the renting of units in a building in which he resided.