Loveridge v. R., [1998] 2 C.T.C. 2266 -- text
Bowie T.C.J.:
Bowie T.C.J.:
Bowie, J.T.C.C.:
1 The Appellant, when filing his income tax return for the taxation year 1994, claimed both a credit for tuition under section 118.5 of the Income Tax Act (the Act), and an education credit under section 118.6. These were disallowed by the Minister of National Revenue on reassessment.
Beaubier T.C.J.:
1 These appeals were heard on common evidence in Toronto, Ontario on May 14 and 15, 1997.
2 The Appellants testified and called John R. McDougall, Mrs. McDougall's husband; Catherine Sharpe, Mrs. McDougall's daughter; Michael Tilley, C.A.; and Michael Fraser, C.A., Mrs. Fraser's son. The Respondent did not call any witnesses.
Watson D.J.T.C.:
1 This appeal was heard under the Informal Procedure in Toronto, Ontario on December 9, 1997.
Bowie T.C.J.:
Bowie T.C.J.:
1 The Appellant appeals from her reassessment for income tax for the 1980 taxation year. In filing her return she claimed to be entitled to take into account in computing her income for taxation purposes a business loss in the amount of $2,005.00 suffered in connection with the business of distributing a speed reading course called “The Advanced Reading Course” (the course).
Lamarre Proulx T.C.J.:
1 These are appeals for the 1989, 1990, 1991 and 1992 taxation years.
Archambault T.C.J.:
Margeson T.C.J.:
1 The matter before the Court at this time for decision is that of Laurie Gee and Her Majesty The Queen, 96-4120(IT)I. The sole question for determination is whether or not during the 1992, 1993 and 1994 taxation years, the Appellant, Laurie Gee, was entitled to claim the deductions in question which have been disallowed by the Minister, the amounts of $6,403, $8,519 and $10,177, respectively.
Linden J.A.: