A W Prociuk (orally: February 24, 1975):

1 The appellant, Marcel Provost, appeals from the respondent's notices of reassessment dated May 10, 1973 wherein certain expenses claimed by him in the taxation years 1969, 1970 and 1971 were disallowed on the ground that he was not entitled to such deductions by reason of his employment. The amounts disallowed are as follows: for the year 1969 $1,383.64; for the year 1970 $2,311.90; for the year 1971 $1,979.06.

Hamlyn T.C.J.:

• (a) including in taxable income the amount of $40,000 as the Appellant's portion of a taxable capital gain of a partnership; and

• (b) allowing a net capital loss of $19,237 on the disposition of an interest in a partnership.

Rip T.C.J.:

Bonner, T.C.J.:

Lamarre Proulx T.C.J.:

1 The Appellant is appealing by way of the informal procedure the reassessments of the Minister of National Revenue (the “Minister”) for the 1992, 1993 and 1994 taxation years.

2 The question at issue is whether the Appellant was carrying on a rental operation the principal purpose of which was to make a profit, or in other words, a rental operation which was a genuine commercial undertaking.

Rip T.C.J.:

Sarchuk T.C.J.:

1 This is an appeal by Canadian Imperial Bank of Commerce (the Appellant from an assessment for income tax with respect to its 1977 taxation year, wherein the Minister of National Revenue (the Minister) disallowed certain deductions claimed by it pursuant to former paragraph 20(1)(gg) of the Income Tax Act (the Act).

Bonner T.C.J.:

1 This is an appeal from an assessment of income tax for the 1990 taxation year. The issue is whether the Appellant suffered a non-capital loss of $65,895.00 in the year. The loss is said to have resulted from the write down to market value of the inventory of a business, that inventory consisting of 9,000 shares of Trilon Financial Corp.

Bell T.C.J.:

1 The taxation years under appeal are 1987, 1988 and 1989.

Issues:

• 1. Whether, under subsection 15(1) of the of the Income Tax Act (the “Act”), a benefit was conferred by Billvest Ltd. (“Billvest”) on its sole shareholder, the Appellant, in the total amount of $1,039,243,

McArthur T.C.J.:

1 These appeals are under the informal procedure concerning the Appellant's 1991, 1992 and 1993 taxation years. They involve the disallowance of expenses from a gravel mining operation and the rental of farm land for hay harvesting.