Currie v. Minister of National Revenue, [1975] C.T.C. 2091, 75 D.T.C. 57 -- text
Roland St-Onge:
1 This is an appeal from a reassessment dated June 26, 1973, wherein a tax was levied in respect of the 1972 taxation year.
Roland St-Onge:
1 This is an appeal from a reassessment dated June 26, 1973, wherein a tax was levied in respect of the 1972 taxation year.
Judge Flanigan (orally: November 22, 1974):
1 For the reasons given this day in the appeal of the Estate of John McGraw v. MNR it is ordered and adjudged that the appeal herein in respect of the 1971 taxation year be and the same is hereby allowed and the matter referred back to the respondent for reassessment accordingly.
Lucien Cardin, Q.C.:
McArthur T.C.J.:
1 These appeals are from reassessments for the 1992 and 1993 taxation years concerning the disallowance of rental losses sustained by the Appellant on a one bedroom condominium in Whistler, British Columbia. The losses were disallowed on the ground that he had no reasonable expectation of profit.
Gibson, J (orally):
1 This appeal is from reassessments for income tax for the 1970 and 1971 taxation years of the plaintiff.
The Assistant Chairman:
1 This is the appeal of Joseph Berman from an income tax assessment in respect of his 1967 taxation year. By agreement of counsel for both parties, the appeal of Joseph Berman was heard simultaneously and on common evidence with those of Mrs Ida Berman and Mrs Pearl Lighter.
The Assistant Chairman:
1 This is the appeal of Reny Barki from an income tax assessment in respect of the appellant's 1972 taxation year.
2 The issue in this appeal is the assessment by the Minister of National Revenue for the payment by the taxpayer of a 15% non-resident tax in the amount of $70.30 and a penalty and interest charge in the amount of $5.
A J Frost:
1 This is an appeal from four assessments each dated November 16, 1973, in respect of appellant's 1967, 1968, 1969 and 1970 taxation years. The appeal was heard on November 29, 1974, at the City of Toronto. It was agreed that the appeals of Plan B Leasing Limited, Plan C Leasing Limited, Strathearn Holdings Limited and Calfonta Investments Limited be heard together with this appeal on common evidence and that any decision reached would apply to the five appeals.
Jackett, CJ, Le Dain, J, MacKay, DJ:
1 The reasons for judgment in this case are identical to those given in Hans Reicher v. The Queen.
A W Prociuk:
1 It is ordered and adjudged that the appeals in respect of the 1970 and 1971 taxation years be and the same are hereby allowed in accordance with the reasons for judgment issued herewith [see Gordon Singer v. MNR, p 2066].