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.

Bowman T.C.J.:

1 These appeals are from loss determinations made under the Income Tax Act for the 1981, 1982 and 1983 taxation years. The narrow question is whether the cost of “acquiring” zoning from a landowner across the street that would permit a greater density is a cost of land or building or, if neither, whether it is an eligible capital expenditure.

Tremblay T.C.J.:

1 This appeal was heard under the informal procedure on April 29, 1997 at Montréal, Quebec.

1. Point at issue

2 According to the Notice of Appeal and the Reply to the Notice of Appeal, the question is whether the appellant is entitled to claim a non-refundable equivalent-to-married tax credit of $914.60 ($5,380 × 17%) for a wholly dependent person, his daughter Nadia.