George Lin

The appellant corporation claimed expenditures for developing a shelf-stable, cold-pressed juice beverage as scientific research and experimental development (SR&ED).

The Minister disallowed the claim, arguing the project involved routine product development without technological uncertainty.

The Tax Court of Canada allowed the appeal, finding that the appellant faced a technological uncertainty regarding microbial growth that could not be resolved by routine engineering.

The Court concluded the appellant formulated hypotheses, followed a scientific method, achieved a technological advancement by successfully using a novel preservative, and maintained adequate documentation.

The matter was referred back to the Minister for reassessment.

The appellant appealed reassessments of her 2011, 2012, and 2013 taxation years, disputing the Minister's denial of various claimed business expenses due to inadequate records.

The Tax Court of Canada allowed the appeal in part, permitting additional deductible expenses for the 2011 taxation year based on the principle that some expenses must have been incurred to earn the reported income, while upholding the late filing penalties.

The appellant failed to file his 2009 tax return on time, prompting the Minister to issue an assessment under subsection 152(7) of the Income Tax Act based on T4 slips.

The appellant later filed a return claiming the income was business income and deducting significant undocumented expenses.

The Tax Court of Canada dismissed the appeal, finding that the appellant provided no documentary evidence or records to rebut the Minister's assumptions or substantiate the claimed business expenses.

The appellant, a commuter train operator, appealed reassessments denying employment expenses for meals and lodging claimed under paragraph 8(1)(g) of the Income Tax Act for the 2014 and 2015 taxation years.

The Tax Court of Canada found that the appellant failed to establish that his duties required him to regularly travel away from the municipality and metropolitan area where he reported to work.

The court concluded that the deduction is not intended for employees who choose not to return home for personal reasons.

The appeal was dismissed without costs.