Paul v. Minister of National Revenue, [1997] 3 C.T.C. 2577 -- text
Rowe T.C.J. (orally):
Rowe T.C.J. (orally):
Garon T.C.J.:
1 This is an appeal from an income tax assessment for the 1992 taxation year. By his assessment the Minister of National Revenue included in the appellant's income inter alia the principal portion, amounting to $10,056.63, of funds from an RRSP paid to the appellant during 1992 totalling $19,219.30.
Léger D.J.T.C.:
1 The Appellant, who happens to be a lawyer, was employed with the Translation Bureau of New Brunswick for a period of seven years from 1987 to 1993. She acted as co-ordinator for Court interpreters. Her place of work was Bathurst, New Brunswick. The employment consisted of training, evaluating court interpreters and being a liaison officer between judges, lawyers, court interpreters and the Translation Bureau.
MacGuigan J.A. (Robertson, McDonald, JJ.A., concurring):
1 We have not been persuaded that Sobier J.T.C.C. made any errors in his consideration of this case.
Beaubier T.C.J.:
Dubé J.:
Watson D.J.T.C.:
1 This appeal was heard at Sherbrooke, Quebec on April 25, 1996 under the informal procedure. The appeal relates to the 1992 and 1993 taxation years.
2 When the appellant filed his tax returns for the 1992 and 1993 taxation years, he claimed a tax credit of $719.61 ($4,233 × 17%) for a severe and prolonged mental or physical impairment in calculating his total non-refundable tax credits. He provided a duly completed form T2201 to this effect.
Brulé T.C.J.:
1 The Appellant brings this appeal against an assessment under the Income Tax Act (the “Act”) for the year 1991, as confirmed by the Minister of National Revenue (the “Minister”) on December 6, 1996. The appeal involves the Appellant's share of a loss claimed by him in a partnership with his ex-wife and another.
A J Frost:
A J Frost:
1 I shall now give my decision in the above income tax appeal from an assessment pertaining to the 1971 taxation year, wherein the Minister of National Revenue assessed the appellant on his share of profits realized on the sale of an apartment building.
2 The appeals of Murray Armel, Joseph C Goldenberg and Gordon Atlin were heard, together with this appeal, on common evidence.