The appellant appealed reassessments for the 2006, 2007, 2008, 2012, and 2013 taxation years, challenging disallowed business losses, business investment losses, rental expenses, and gross negligence penalties.
The Tax Court of Canada upheld the disallowance of the business losses and business investment losses, finding no evidence of actual businesses or investments.
The court also upheld the gross negligence penalties, finding the appellant demonstrated an indifference to whether the law was complied with.
The appeal was allowed in part, based on the respondent's concessions, to reduce a 2008 capital gain and allow rental repair expenses for 2012 and 2013.
