The Chairman:—This is an application by Savary Beach Lands Ltd and Savary Resort Properties Ltd (under section 167 of the Income Tax Act, as amended by 1970-71-72, c 63) for leave to file Notices of Objection in respect of the 1967
A W Prociuk:—The appellant herein appeals from the assessment for the taxation year 1967 by the Minister who determined his taxable income for that year to be $173,293.82. Taxes assessed were as follows: federal— $72,809.98; provincial — $28,229.44, together with interest
The Chairman:—This is an appeal by the taxpayer against notices of reassessment of income tax for the years 1966 and 1967 issued by the Minister of National Revenue in September of 1969.
A J Frost (orally):—This is an income tax appeal in respect of the appellant’s 1965 taxation year. Upon notice of objection duly signed and filed, the Minister of National Revenue confirmed the assessment on June 10, 1971. The appeal came on for hearing in
A J Frost:—This taxpayer has appealed from assessments to income tax with respect to income for the taxation years 1962 through 1967. The underlying facts and issues are identical to those in the appeal of Jack Abugov v MNR. At the hearing, it was agreed that the evidence and argument rendered would apply equally to both cases, the only slight difference being the amounts of the adjustments made by the respondent to appellant’s income.
A J Frost:—This income tax appeal is in respect of appellant’s 1962, 1963, 1964, 1965, 1966 and 1967 taxation years. Upon Notice of Objection duly signed and filed, the Minister of National Revenue reconsidered the assessments and confirmed them on May 14, 1970.
A W Prociuk:—This is an appeal from an assessment for the taxation year 1968 wherein the Minister ruled that the net proceeds of sale of land by the appellant was taxable income.
A W Prociuk:—The appellant appeals from the Minister’s assessment for the year 1965 wherein an additional $1,643.07 was added to the appellant’s declared income for that year.
A W Prociuk:—The appellant was disallowed farming losses incurred in the years 1967 and 1968 to be deducted from his other income and this is the subject matter of this appeal.
A W Prociuk:—The point to determine in this appeal is whether or not the appellant during the years 1966 and 1967 carried on the business of farming with a reasonable expectation of profit and was entitled to deduct his farming expenses from his other
