The appellants appealed reassessments denying a terminal loss deduction, including shareholder benefits, and reducing capital cost allowance claims related to a co-ownership property.
The Tax Court of Canada dismissed the appeals, finding that the Minister was justified in reassessing beyond the normal period due to misrepresentations attributable to neglect, that the property units sold to family members were personal-use property not eligible for a terminal loss, and that the fair market value of the commercial unit was correctly assessed by the Minister's expert.