Tax Court of Canada

Any legal expenses to protect rights to obtain future income were not deductible

Tax – Income tax – Employment income

There was no material evidence of commercial effort

Tax – Income tax – Tax avoidance

Notes were debt during taxation year in issue, although amounts to be paid weren’t yet ascertained

Tax – General principles – Interpretation of taxing statutes

Taxpayers failed to usher any evidence to refute Minister’s assumptions

Tax – Income tax – Administration and enforcement

If dividend was repayment of loan there would be no debt remaining afterward

Tax – Income tax – Administration and enforcement

Reassessments were valid and binding until set aside by Tax Court of Canada

Tax – Income tax – Administration and enforcement