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Reasons for Judgment Watson, D.J.T.C.C. [1] This appeal was heard in Regina, Saskatchewan on August 5, 1999 under the Informal Procedure. [2] In computing income for the 1993, 1994 and 1995 taxation years, the appellant deducted the amounts of $16,316.63 and $12,438.09 as farm losses for the 1993 and 1994 taxation years respectively and $8,750.00 for 1995 as a farm loss pursuant to subsection 31(1) of the Income Tax Act (the " Act ") as follows:      1993    1994 Income: Canadian Wheat Board Payments: $ 952.24       nil Rebates        339.98       nil Total Income    $ 1,292.22 $     nil Expenses: Forage     $ 401.25 $      nil ContractWork/Seed Cleaning         nil      348.50 Machinery      2,946.71    2,891.35 Motor Vehicle      1,127.44      434.85 Fence Repairs          nil      125.50 Containers/Twine/Bailing Wire         nil      480.07 Small Tools       244.79      324.78 Insurance       412.00         nil Accounting/Legal/Office      128.31      391.63 Telephone/Electricity/Heating     1,681.11    2,281.12 House        579.84         nil Water        67.93         nil Capital Cost Allowance (CCA)    9,434.82    3,366.33 Interest        191.92    1,050.78 Property Taxes      392.73      743.18 Total Expenses: $17,608.85 $12,438.09 Net Loss    ($16,316.63) ($12,438.09)     1995 Income:   ________ Rebates    $ 476.12 Total Income    $ 476.12 Expenses: Pesticides    $    341.71 Machinery      4,396.20 Motor Vehicle      1,044.36 Building and Fence Repairs     1,626.13 Small Tools        32.47 Insurance/NISA ACS       559.00 Accounting/Legal/Office      333.75 Telephone/Electricity/Heating/    1,782.42 Water        113.85 Capital Cost Allowance (CCA)    9,383.96 Interest      2,942.93 Property Taxes      195.88 Total Expenses: $22,752.66 Net Loss    ($22,276.54) Allowable Farm Loss ($ 8,750.00) Restricted Farm Loss ($13,526.54) [3] In reassessing the appellant for these three taxation years, the Minister of National Revenue (the "Minister") disallowed the deduction of these losses, making the following assumptions of fact: "(a) the facts admitted and stated supra: (b) during the 1992, 1993, 1994, 1995 and 1996 taxation years the Appellant was employed on a full-time basis and received employment income for each year as follows: Year Employment Income 1992 $27,480.00 1993    19,278.00 1994    24,519.00 1995    38,609.00 1996    31,813.00 (c) the Appellant carried on the business of farming on a full-time basis up to 1988; (d) in 1988, the Appellant sold a portion of the land on which he was farming and commenced to be employed; (e) the Appellant became bankrupt in 1991; (f) subsequent to the bankruptcy, the Appellant reacquired, for $20,000.0, 40 acres of land previously owned by him and which contained his residence and some surrounding buildings; (g) subsequent to the bankruptcy, the Appellant commenced the activity of growing and baling alfalfa (the "Activity") on that portion of the 40 acres of land that was not covered by the yard site, including the surrounding buildings and corrals; (h) the Appellant reported the following losses from the Activity in the 1991 and 1992 taxation years: TAXATION GROSS NET YEAR INCOME EXPENSES LOSS 1991 $ 687.00 $ 8,087.00 ($ 7,400.00) 1992 4,694.00 18,288.00 (13,594.00) (i) the Appellant reported the following loss from the Activity in the 1996 taxation year: TAXATION GROSS NET YEAR INCOME EXPENSES LOSS 1996 $1,850.00 $5,851.00 ($4,001.00) (j) during the years under appeal, the Appellant did not take any steps or make any plans to develop or expand the Activity, nor has he taken any steps to do so since that time; (k) the amount of land used by the Appellant in the Activity is not large enough in order to allow the Appellant to generate sufficient gross income to cover the expenses incurred; (l) the Appellant did not have a reasonable expectation of profit from the Activity during the 1993, 1994 and 1995 taxation years; (m) the expenses claimed in relation to the Activity were personal or living expenses of the Appellant. ...

Signed at Ottawa, Canada, this 23rd day of December 2005.       Rip J.     ... Signed at Ottawa, Canada this 23rd day of December 2005.       Rip J.   ... Gauthier Josée Vigeant   Counsel for the Respondent: Daniel Bourgeois   COUNSEL OF RECORD:   For the Appellant:   Name: André P. ...

Signed at Ottawa, Canada, this  6 th day of October, 2010.         “G. ... Sheridan” Sheridan J.         Citation: 2010TCC406 Date: 2010 1006 Docket: 2008-1251(IT)G BETWEEN: STEPHEN STOW, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... Signed at Ottawa, Canada, this 6 th day of October, 2010.         “G. ...

    « Lucie Lamarre » Lamarre J.           Citation: 2011 TCC 314 Date:20110622 Docket: 2010-3541(IT)I BETWEEN: Scot A. Ladell, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       REASONS FOR JUDGMENT     Lamarre J ...   [16]          The appeal is dismissed.     Signed at Ottawa, Canada, this 22 nd day of June 2011.     ...

The Queen, 2013 TCC 250     Docket: 2011-3160(IT)G BETWEEN: DENIS GÉLINAS, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   [OFFICIAL ENGLISH TRANSLATION]     Appeal heard on June 21, 2013, at Montréal, Quebec.   ...         “ Gaston Jorré ” Jorré J.     Translation certified true on this 11th day of February 2014.     ...

Rip” Rip C.J.           Citation: 2014 TCC 12 Date: 20140114 Docket: 2008-2896(IT)G BETWEEN: CONRAD BLACK, Applicant, and   HER MAJESTY THE QUEEN, Respondent.   ...   [69]         The parties may make submissions in writing as to costs within 60 days.     ... Bornstein Diana Aird   COUNSEL OF RECORD:          For the Appellant:                             Name:                     David C. ...

The Queen, 2007 TCC 708 (Informal Procedure)   Docket: 2006-2334(IT)I BETWEEN: JEAN MCALLISTER, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... Sheridan   Appearances:   For the Appellant: The Appellant herself     Counsel for the Respondent: April Tate   JUDGMENT             In accordance with the attached Reasons for Judgment, the appeals of the 2001, 2002, 2003 and 2004 taxation years are allowed. ...     [14] [1993] 1 C.T.C 2333.   [15] Bishop, supra at paragraph 44.   [16] Bishop, supra at paragraph 45 ...

Little” Little J.           Citation: 2011 TCC 117 Date: February 22, 2011 Docket: 2009-3112(EI)APP BETWEEN: CRYSTAL L. COURTNEY, Applicant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.       ... ISSUES   [20]          The issues are:             1.       Does the Tax Court have jurisdiction to hear this matter?             ...

Rip” Rip C.J.             Translation certified true on this 26th day of April 2013.         ...   [16]         The appeal is dismissed.       Signed at Ottawa, Canada, this 7th day of February 2013.         ...

Signed at Ottawa, Canada, this 11 th day of March 2011.       “G. A. Sheridan” Sheridan J.       ... Signed at Ottawa, Canada, this 11 th day of March 2011.       “G. A. Sheridan” Sheridan J.   ...