The Appellants appealed reassessments disallowing losses from dog-related activities and rental properties.
The Tax Court found that the Minister was precluded from reassessing certain years outside the normal reassessment period, except for specific personal expenses.
The Court determined that the dog-related activities were not a source of income, but the rental properties were.
The repeated-failure-to-file penalties were vacated, while the late-filing penalty for 2009 was upheld.