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In making these assessments the Minister assumed the facts set out in Paragraph 4 of the Reply to the Notice of Appeal, which read as follows: [TRANSLATION] (a) the deduction for contribution to an RRSP in the 1993 taxation year was allowed at the maximum permitted by the Income Tax Act (“the Act”) and was calculated as follows: 1993 taxation year Calculation of 1992 earned income: Income $36,186 Less: union dues (110) Subtotal 36,076 Plus: R.R.Q. disability pension 8,368 farming profit 1,658 Subtotal 46,102 Less: rental loss (1,151) Total 44,951 1993 taxation year Rate x 18% RRSP deductible before adjustment 8,091 Less: 1992 pension adjustment (6,762) Maximum amount deductible for RRSP $ 1,329 in 1993 (b) the deduction for contribution to an RRSP in 1994 taxation year was allowed at the maximum permitted by the Act and was calculated as follows: 1994 taxation year Calculation of 1994 earned income: Income $37,119 Less: union dues (115) Subtotal 37,004 Plus: R.R.Q. disability pension 8,519 Subtotal 45,523 Less: rental loss (903) farming loss (214) Total 44,406 Rate x 18% RRSP deductible before adjustment 7,993 Less: 1993 pension adjustment (6,939) Maximum amount deductible for RRSP $1,054 in 1994 (c) on June 25, 1996 the Minister affirmed the appellant’s income tax assessments for each of the 1993 and 1994 taxation years. ...

The next two items are amounts of $528.00 and $ 1,000.00, supported by cancelled cheques written to J.S. ...

Justice McKenzie’s order of December 5, 1994 are deductible by him under paragraph 60(c) of the Income Tax Act which in 1993 and 1994 permitted a deduction as follows: (c) maintenance — an amount paid by the taxpayer in the year as an allowance payable on a periodic basis for the maintenance of the recipient, children of the recipient or both the recipient and the children, if (i) at the time the amount was paid and throughout the remainder of the year the taxpayer was living separate and apart from the recipient, (ii) the taxpayer is the natural parent of a child of the recipient, and (iii) the amount was received under an order made by a competent tribunal in accordance with the laws of a province. ...

Counsel concluded that these oppression provisions provide the remedy of an aggrieved shareholder — for example, a shareholder who did not receive dividends in the priority established by the Articles. ...

Numerous taxpayers have raised the Fourth Amendment or equal protection arguments in an attempt to quash notices of deficiency — and have been notably unsuccessful. ...

In 1984 there were total expenses claimed of $ 14,052.39, a gross income of $2,395 for a net loss of $11,657.39. ...

Subparagraph ii) does not contain the words "... in the course of or by virtue of his office or employment...”. ...

Cooper Inc. calculated the capital cost allowance (“CCA”) for the aircraft and its operating expenses as follows: [1] 1992 1993 1994 Depreciation ($22,520.00) ($41,302.97) ($30,977.50) Operating Expenses (0.00) ($16,813.97) ($ 7,945.00) Total Expenses per ($22,520.00) ($58,116.94) ($38,922.5) Fin. ...

Gray has repaid all the loans and associated interest to me on the following basis: 1986 CAD 2,000.00 1987 CAD 15,000.00 + USD 10,000.00 1988 CAD 354,500.00 1989 CAD 157,500.00 1991 CAD 22,500.00 1992 CAD 468,750.00 6. ...

In so reassessing the appellant for the 1992 and 1993 taxation years, the Minister made the following assumptions of fact: (a) At all material times, the appellant was employed full-time as a commission salesman for Southey Farm Supply, which is located in Southey, Saskatchewan, approximately 200 kilometers from the farming property; (b) The time committed to the farming operation was minimized due to the full-time employment of the appellant as a sales representative; (c) In or about the month of February, 1991, the appellant purchased a residence in Regina in order to be located closer to his place of employment, which residence is significantly closer to his place of employment than the farm property at Saltcoats; (d) In 1991, the appellant sold a quarter section of farm property; (e) The appellant rented and occupied the Regina residence prior to his purchase of the said property; (f) The appellant earned the following amounts from his employment during the 1989 through 1990 taxation years respectively: Taxation Year Income 1989 $33,840 1990 38,687 1991 40,400 1992 58,009 1993 61,609 1994 64,838 1995 62,967 (g) Apart from the 1985 taxation year for which the appellant reported a profit in the amount of $5,179 during the taxation years 1979 through 1995, the appellant reported consistent annual losses from his farming operation; (h) With respect to that period, the appellant reported farming income (losses) as follows: Taxation Year Gross Income 1979 $73,238 1980 51,925 1981 75,455 1982 74,769 1983 95,935 1984 99,453 1985 55,219 1986 59,699 1987 51,141 1988 51,001 1989 59,292 1990 65,035 1991 90,583 1992 74,600 1993 40,998 1994 77,643 1995 36,771 Expenses Net Income (Loss) $80,373 ($ 7,135) 63,850 (11,925) 88,123 (12,668) Expenses Net Income (Loss) 89,421 (14,962) 109,051 (13,116) 102,640 (3,187) 50,040 (5,179) 64,335 (4,636) 51,686 (582) 62,153 (11,152) 84,307 (25,015) 98,175 (33,140) 125,747 (35,164) 115,643 (41,043) 99,252 (38,254) 113,713 (36,040) 82,369 (45,598) (1) Notwithstanding the significant losses over the previous 15 years, the appellant has no plans to alter the manner or type of farming operation from that of its present undertaking; (j) The appellant’s chief source of income during the taxation year was neither farming nor a combination of farming and some other source of income. ...