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.: — This is an appeal from an assessment of income tax for the appellant’s 1991 taxation year. ...

.: — These appeals are against assessments with respect to the Appellant’s 1991-1992 taxation years. ...

.: — This appeal was heard under the informal procedure at Québec, Quebec on January 8, 1996. 1. ...

.: — This appeal was heard in Edmonton, Alberta under the Informal Procedures of this Court for the Appellant’s 1992 taxation year. ...

.: — These appeals are governed by the informal procedure provided for under section 18 and following sections of the Tax Court of Canada Act. ...

(orally): — Mr. Adusei, in this country we have several levels of court. ...

Thill & Associates Inc. (“Thill”) which promoted the sale to Canadians of licenses to sell the course in specified territories in the U.S.A.. ...

Subsection 63(1) of the Income Tax Act reads as follows: “earned income” — “earned income” of a taxpayer means the total of (a) all salaries, wages and other remuneration, including gratuities, received by the taxpayer in respect of in the course of, or because of, offices and employments, (b) all amounts that are included or that would, but for paragraph 81(1)(a), be included because of section 6 or 7 or paragraph 56(1)(m), (n) or (0), in computing the taxpayer’s income, (c) all the taxpayer’s incomes or the amounts that would, but for paragraph 81(1)(«), be the taxpayer’s incomes from all businesses carried on either alone or as a partner actively engaged in the business, and (d) all amounts described in paragraph 56(8)(a) received by the taxpayer in the year; The questions that remains is whether subsection 63(3) envisions that unemployment insurance benefits are to be included in the computation of earned income. ...

T.D.). 5 Ibid„ at p. 584. 6 This practice is illustrated in A & E Land Industries Ltd. v. ...

C.A.) at page 5454 where Mahoney J.A. stated: … The failure to record transactions will inevitably handicap a taxpayer seeking to discharge the burden of proving that they took place but the responsibility of the trial judge in such circumstances is to decide, on a balance of probabilities having regard to all the evidence and its credibility, whether any, all or none took place. ...