Enstone v. Canada (2000)

Extract

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Enstone v. Canada (2000)

Date: 20000214

Docket: A-594-98

CORAM: STRAYER J.A.

SHARLOW J.A.

MALONE J.A.

BETWEEN:

J. BRUCE ENSTONE

Appellant

- and -

HER MAJESTY THE QUEEN

Respondent

Heard at Ottawa, Ontario, on Wednesday, January 19, 2000

Judgment delivered at Ottawa, Ontario, February 14, 2000

REASONS FOR JUDGMENT BY: SHARLOW J.A.

CONCURRED IN BY: STRAYER J.A.

MALONE J.A.

Date: 20000214

Docket: A-594-98

CORAM: STRAYER J.A.

SHARLOW J.A.

MALONE J.A.

BETWEEN:

J. BRUCE ENSTONE

Appellant

- and -

HER MAJESTY THE QUEEN

Respondent

REASONS FOR JUDGMENT

SHARLOW J.A.

[1] The appellant Mr. Enstone, in filing his income tax returns for 1991, 1992, 1993 and 1994, claimed deductions for expenditures he made in respect of three properties, 418-420 Hinton Avenue and 132 Faraday Street in Ottawa. He claims that those properties comprise a rental business. Initially all of the deductions were disallowed on the basis that there was no reasonable expectation of profit. Mr. Enst...

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