Randall S. Bocock

The appellant appealed reassessments disallowing business losses claimed in the 2013 and 2014 taxation years in relation to abstract photography and string quartet endeavours.

The Tax Court of Canada dismissed the appeal, finding that neither endeavour constituted a source of business income.

The appellant conceded the string quartet endeavour was not a business, and the court found the photography endeavour lacked the necessary hallmarks of commerciality to be considered a business undertaken in pursuit of profit.

The appellants, two individuals and their respective restaurant corporations, appealed reassessments for unreported sales, shareholder benefits, and gross negligence penalties.

The Minister used arbitrary assessment methods after discovering that the restaurants' point-of-sale systems had been manipulated to delete cash sales.

The Tax Court of Canada upheld the assessments, finding that the Minister's methodology was sound and that the appellants failed to demolish the Minister's assumptions.

The Court also upheld the shareholder benefits and gross negligence penalties, concluding that the individual appellants knowingly participated in the suppression of sales data and appropriation of corporate cash.

The appellant appealed the Minister's arbitrary assessments for the 2011, 2012, and 2013 taxation years, which were issued after he failed to file tax returns.

He challenged the denial of disability tax credits, the imposition of late filing penalties and arrears interest, and the disallowance of employment expenses.

The Tax Court of Canada dismissed the appeal, finding no evidence to support the disability tax credit claim, no valid due diligence defence for failing to file returns, and insufficient, unreliable evidence to substantiate the claimed employment expenses.