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The Tax Court Judge found that the appellant provided no credible explanation for the amounts of unreported sales revenue reflected in the reassessments. [5] The Tax Court Judge considered the concessions made by the appellant’s representative, the oral testimony of an auditor and the appellant, as well as documentary evidence. ...

.), the Court of King’s Bench considered whether judicial compensation granted by the court in the exercise of its discretionary authority only existed by virtue of a judgment or whether it should be retroactive to the date of the principal claim or of the counterclaim. ...

Rankin, and the changes in American tax law had a negative and unexpected impact on the business, no evidence was presented to show what profit the taxpayer might have earned had these events not occurred and whether the amount would have been considered substantial when compared to his professional income. ...

This procedure does not meet the requirements laid down by the Act for support payments to be considered deductible. ...

In 1991, Parliament clarified its position by defining the meaning of the expression “basic activities of daily living”: 118.4(1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and thi# subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet settling, another person familiar with the individual, (v) eliminating (bowel and bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

The only item at issue is whether this appeal should be considered a Class “A” or a Class “B” action, for the purposes of determining costs. ...

The authorities pertinent to the foregoing were recently considered by Thurlow, ACJ, and need not be recited here.t [4] It was not argued that the fact the services by which the wages were earned were performed off the Gull Bay Reserve is determinative of anything. ...

In his use of the term “over-optimism” he had reference to the projections of earnings of Halifax Parking Limited made by the appellant’s experts which clearly he considered to have been in each case exaggerated. ...

She also presents her husband’s income as “income from self-employment”. 3.09 In filing her own 1976 income tax return, the appellant considered the amount of $7,055.87 as death benefit and did not include it in her income. 3.10 By assessment dated August 2,1977, the respondent included the said amount in the appellant’s income. 3.11 On October 7, 1977, the appellant filed a notice of objection. 3.12 On March 28,1978, the respondent issued a notice of reassessment by which it confirmed the inclusion in the appellant’s income of the amount of $7,055.87. 3.13 On June 20, 1978, the appellant lodged a notice of appeal before the Tax Review Board. 4. ...

In Gladys (Geraldine) Evans v MNR, [1960] CTC 69; 60 DTC 1047, (a case to which neither counsel referred) the Supreme Court of Canada considered the question whether legal fees spent by a taxpayer in an attempt to establish an entitlement to an annual income for life were deductible. ...