The taxpayer appealed a tax reassessment for his 2011 taxation year, which was issued beyond the normal reassessment period.
The Minister had disallowed rental losses, reduced business expenses, and added an unreported capital gain from the transfer of a property to his son.
The Tax Court found that the rental properties were a personal endeavor and not a source of income, and that the disallowed business expenses were either personal or unreasonable.
The Court also upheld the Minister's right to reassess beyond the normal period due to misrepresentations attributable to neglect or carelessness.
However, the Court allowed the appeal in part to increase the adjusted cost base of the transferred property, reducing the taxable capital gain to $14,437.