Date: 20020207
Docket: 2001-300-IT-I
BETWEEN:
WILLIAM J. TROUPE,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
Reasons for Judgment
Lamarre, J.T.C.C.
[1] This is an appeal under the informal procedure from an assessment made by the Minister of National Revenue ("Minister") under the Income Tax Act ("Act") with respect to the appellant's 1999 taxation year. In computing his tax payable for that year, the appellant claimed, under non-refundable tax credits, a tuition credit in the amount of $888 and an education tax credit in the amount of $240 that were transferred to him in his capacity as a supporting person by his daughter, Amanda Christine Troupe, pursuant to section 118.9 of the Act.
[2] In assessing the appellant, the Minister disallowed both the tuition and the education tax credits, which totalled $1,128. The Minister's reasons for denying the tuition and education tax credits are set out in paragraph 10 of the Reply to the Notice of Appeal as follows:
a) at all material times, the Appellant had a daughter, Amanda Christine Troupe, born January 6, 1987 (the "Child");
b) during the period September, 1999 to December, 1999, the Child was enrolled as a student at the School of Dance (the "Institution") and undertook a course entitled Professional Program in Ballet (the "Course");
c) the Institution is listed as a certified educational institution within the meaning of subparagraph 118.5(1)(a)(ii) of the Income Tax Act (the "Act");
d) an amount of $888.00 was paid for the Child's enrollment at the Institution with respect to the Course and the said amount was indicated on form T-2202A (Tuition and Education Amounts Certificate) issued by the Institution;
e) a total of $240.00 representing part time attendance for the four month period from September, 1999 to December, 1999 was also indicated on form T-2202A and the said amount represented an education amount for the said period;
f) the amounts of $888.00 and $240.00 referred to in subparagraphs 10(d) and 10(e) herein respectively represent the total of $1,128.00 claimed by the Appellant as tuition and education amount transferred from a child and referred to in paragraphs 7 and 9 herein;
g) the Child had not attained the age of 16 years before the end of the 1999 taxation year;
h) it has not been shown that the Child was working towards an occupation or improving her skills in an occupation by taking the Course; and
i) the purpose of the Child's enrollment at the Institution cannot reasonably be regarded as being to provide the Child with skills, or to improve the Child's skills, in an occupation.
[3] The transfer to a parent of the tuition and education tax credits is dealt with in sections 118.5, 118.6 and 118.9 of the Act, the relevant portions of which, as applicable for the taxation year at issue, are reproduced below:
SECTION 118.5: Tuition credit.
(1) For the purpose of computing the tax payable under this Part by an individual for a taxation year, there may be deducted,
(a) where the individual was during the year a student enrolled at an educational institution in Canada that is
(i) a university, college or other educational institution providing courses at a post-secondary school level, or
(ii) certified by the Minister of Human Resources Development to be an educational institution providing courses, other than courses designed for university credit, that furnish a person with skills for, or improve a person's skills in, an occupation,
an amount equal to the product obtained when the appropriate percentage for the year is multiplied by the amount of any fees for the individual's tuition paid in respect of the year to the educational institution if the total of those fees exceeds $100, except to the extent that those fees
(ii.1) are paid to an educational institution described in subparagraph (i) in respect of courses that are not at the post-secondary school level,
(ii.2) are paid to an educational institution described in subparagraph (ii) if
(A) the individual had not attained the age of 16 years before the end of the year, or
(B) the purpose of the individual's enrolment at the institution cannot reasonably be regarded as being to provide the individual with skills, or to improve the individual's skills, in an occupation,
. . .
4118.6(2)3
(2) Education credit. There may be deducted in computing an individual's tax payable under this Part for a taxation year the amount determined by the formula
A X B
where
A is the appropriate percentage for the year; and
B is the total of the products obtained when
(a) $200 is multiplied by the number of months in the year during which the individual is enrolled in a qualifying educational program as a full-time student at a designated educational institution, and
(b) $60 is multiplied by the number of months in the year (other than months described in paragraph (a)), each of which is a month during which the individual is enrolled at a designated educational institution in a specified educational program that provides that each student in the program spend not less than 12 hours in the month on courses in the program,
if the enrolment is proven by filing with the Minister a certificate in prescribed form issued by the designated educational institution and containing prescribed information and, in respect of a designated educational institution described in subparagraph (a)(ii) of the definition "designated educational institution" in subsection (1), the individual has attained the age of 16 years before the end of the year and is enrolled in the program to obtain skills for, or improve the individual's skills in, an occupation.
SECTION 118.9: Transfer to parent or grandparent.
Where for a taxation year a parent or grandparent of an individual (other than an individual in respect of whom the individual's spouse deducts an amount under section 118 or 118.8 for the year) is the only person designated in writing by the individual for the year for the purpose of this section, there may be deducted in computing the tax payable under this Part for the year by the parent or grandparent, as the case may be, the tuition and education tax credits transferred for the year by the individual to the parent or grandparent, as the case may be.
[4] The Minister assessed the appellant on the basis that he was not entitled to a transfer of the tuition and education tax credits from his daughter Amanda because she did not meet the two requirements imposed by subparagraph 118.5(1)(a)(ii.2) and subsection 118.6(2). The first requirement is that the appellant's daughter have attained the age of 16 years before the end of the 1999 taxation year. The second is that the purpose of her enrolment at The School of Dance can reasonably be regarded as having been to provide her with skills, or to improve her skills, in an occupation.
[5] The appellant submitted evidence to try to establish that his daughter met the second condition. He admits that his daughter was only 12 years old in 1999 but he is of the view that the age requirement in sections 118.5 and 118.6 of the Act is discriminatory within the meaning of subsection 15(1) of the Canadian Charter of Rights and Freedoms ("Charter").
[6] The respondent is of the view that the appellant has not demonstrated that the purpose of his daughter Amanda's enrolment at The School of Dance was to furnish her with skills in an occupation. Counsel argued that a reasonable person would see that Amanda's enrolment in the dance course was more for the purpose of carrying on a hobby or extra-curricular activity than acquiring or improving skills in an occupation within the meaning of the Act. The respondent further submits that clause 118.5(1)(a)(ii.2)(A), subsection 118.6(2) and section 118.9 of the Act do not violate subsection 15(1) of the Charter. In the alternative, counsel submits that, should this Court find the impugned sections of the Act to be discriminatory under section 15 of the Charter, the infringement is justifiable in a free and democratic society under section 1 of the Charter.
[7] Section 1 and subsection 15(1) of the Charter read as follows:
1. The Canadian Charter of Rights and Freedoms guarantees the rights and freedoms set out in it subject only to such reasonable limits prescribed by law as can be demonstrably justified in a free and democratic society.
15. (1) Every individual is equal before and under the law and has the right to the equal protection and equal benefit of the law without discrimination and, in particular, without discrimination based on race, national or ethnic origin, colour, religion, sex, age or mental or physical disability.
A - Purpose of daughter's enrolment at the School of Dance
[8] I will first address the question of whether the purpose of Amanda's enrolment at The School of Dance was to provide her with skills in an occupation. The appellant asked Ms. Merrilee Worsfold-Hodgins, known as Merrilee Hodgins, who has been co-artistic director at The School of Dance for 23 years, to testify. She explained that her school is certified by the Minister of Human Resources Development as an educational institution that provides courses that furnish its students with skills for, or improve their skills in, an occupation. The school offers three distinct programs: a recreational program, a professional training program (divided into three components: classical ballet, modern dance and teacher training) and a public, subsidized program for the betterment of the community. The School of Dance is certified for the purposes of the Act only with respect to the professional training program, in which Amanda is taking courses in classical ballet.
[9] According to Ms. Hodgins, unlike many other professions, in the case of dance, training cannot begin when a student graduates from high school and is ready for university entrance. She explained that the training process of a classical ballet dancer normally begins at the age of 10 and lasts for approximately eight or nine years. At 17 to 19 years of age, the students normally cross over into their professional career, which may extend until the age of 30. After that point, many dancers move into university training or retrain for new careers that are more academically based (see Exhibit A-3).
[10] All students who apply for entrance to the professional training programs at The School of Dance must pass stringent auditions, which are one month in length, in order to be accepted for training, and they are evaluated yearly before reacceptance is confirmed (see Exhibit A-3). The recreational program does not have any of those requirements: anyone can attend courses offered through the recreational ballet program.
[11] In the professional program, at the age of 10, it is appropriate for students to study approximately four hours per week. By the time the students have reached 14 years of age, classes are daily and may last from 1.5 to 2 hours or so (approximately 14 to 16 hours per week). In addition to the year-long program, which generally runs from September through June, dance students are expected to attend a four-week training program during the summer. Recreational students attend the school for only one hour per week and do not have to take part in the summer program. There are fewer students per class in the professional program (between 7 and 15) than in the recreational program (25 per class).
[12] Amanda was in the professional program, year 3 ("PP3") at The School of Dance in 1999, and at the time of the hearing in 2001 she was in the professional program, year 5 ("PP5") (see Exhibit A-4). She had previously taken her grades 2, 3 and 4 Royal Academy of Dance examinations. In 1999, she was practising 10 hours per week. In the summer of 1998 and 1999, she participated in the Royal Winnipeg Ballet's professional division summer program, which accepted students by audition only. Amanda explained that only 120 students (including herself) were accepted in that program out of a total of 1,500 who were auditioned. That summer program involved intensive ballet training. She also appeared in the ballet The Nutcracker with the Royal Winnipeg Ballet in 1999 and then with Les Grands Ballets Canadiens in 2000. She had many rehearsals in preparation for those performances. She now dances 15 or 16 hours per week. She stated very clearly that she is dedicated to dance and that she is focusing most of her energies on becoming a professional dancer. Amanda is also in full-time attendance at a secondary school that provides the support necessary to enable high-level performers in the arts or athletics to pursue successfully their educational and artistic or athletic goals.
[13] In view of the evidence presented before me, I conclude that the appellant has demonstrated that the purpose of Amanda's enrolment in The School of Dance can reasonably be regarded as being to provide her with skills, or to improve her skills, in an occupation.
[14] Counsel for the respondent has submitted that a 12-year-old child's involvement in activities such as ballet lessons is more likely to be a hobby than an occupation leading to employability, taking into account the fact that in such a case "the period of employment is not within a reasonable reach".
[15] Based on the evidence adduced, it does not appear that Amanda was enrolled in the professional ballet program as merely a hobby or extra-curricular activity. Ms. Hodgins made a clear distinction between the recreational program and the professional training program. At the professional PP3 level (the level at which Amanda was training in 1999), approximately 10-12 hours of training a week is required. As regards eligibility for tuition and education tax credits under sections 118.5 and 118.6, I do not see any requirement that the individual eventually produce income from the occupation for which that individual is receiving training, or at least there is no requirement that earning such income be "within a reasonable reach" as argued by the respondent. It is obvious from the evidence that a person cannot become a ballet dancer without taking courses in ballet, and these courses must be started at an early age (10 years old), as stated by Ms. Hodgins in her testimony. Without early professional training, the appellant's daughter could not become a professional ballet dancer.
[16] Furthermore, there is an audition process for the professional program and not everyone is accepted (unlike the recreational program). Therefore, the children who are selected for the professional program are those that The School of Dance determines to have a good chance at becoming professional dancers. In my view, the objective requirement that the purpose of the appellant's daughter's enrolment at The School of Dance can be reasonably regarded as being to provide her with skills, or to improve her skills, in an occupation has been met, based on the evidence of Ms. Hodgins. I would also point out that this is a point that seems to have been accepted without question in the case of Sandford v. Canada, [1998] T.C.J. No. 934 (Q.L.).
B - The Charter Issue
[17] Although the appellant's daughter meets one of the conditions required by sections 118.5 and 118.6 of the Act, she does not meet the other condition, which is that she have attained 16 years of age at the end of 1999. The appellant has raised the point that clause 118.5(1)(a)(ii.2)(A), subsection 118.6(2) and section 118.9 of the Act are discriminatory within the meaning of subsection 15(1) of the Charter.
[18] The purpose of subsection 15(1) was summarized by Iacobucci J. in the following terms in Law v. Canada (Minister of Employment and Immigration), [1999] 1 S.C.R. 497, at p. 549:
Purpose
(4) In general terms, the purpose of s. 15(1) is to prevent the violation of essential human dignity and freedom through the imposition of disadvantage, stereotyping, or political or social prejudice, and to promote a society in which all persons enjoy equal recognition at law as human beings or as members of Canadian society, equally capable and equally deserving of concern, respect and consideration.
(5) The existence of a conflict between the purpose or effect of an impugned law and the purpose of s. 15(1) is essential in order to found a discrimination claim. The determination of whether such a conflict exists is to be made through an analysis of the full context surrounding the claim and the claimant.
[19] The Supreme Court of Canada has stated some of the main guidelines for an analysis under subsection 15(1). These guidelines are provided as points of reference for a court that is called upon to decide whether a claimant's Charter right to equality without discrimination has been infringed.
[20] The approach adopted and regularly applied by the Supreme Court of Canada with respect to the interpretation of subsection 15(1) focuses upon three central issues, as stated in Law, supra, at p. 548:
(A) whether a law imposes differential treatment between the claimant and others, in purpose or effect;
(B) whether one or more enumerated or analogous grounds of discrimination are the basis for the differential treatment; and
(C) whether the law in question has a purpose or effect that is discriminatory within the meaning of the equality guarantee.
[21] Accordingly, a court that is called upon to rule on a discrimination claim under subsection 15(1) should make the following three inquiries, as set out in Law, supra, at pp. 548-549:
(A) Does the impugned law (a) draw a formal distinction between the claimant and others on the basis of one or more personal characteristics, or (b) fail to take into account the claimant's already disadvantaged position within Canadian society resulting in substantively differential treatment between the claimant and others on the basis of one or more personal characteristics?
(B) Is the claimant subject to differential treatment based on one or more enumerated and analogous grounds?
and
(C) Does the differential treatment discriminate, by imposing a burden upon or withholding a benefit from the claimant in a manner which reflects the stereotypical application of presumed group or personal characteristics, or which otherwise has the effect of perpetuating or promoting the view that the individual is less capable or worthy of recognition or value as a human being or as a member of Canadian society, equally deserving of concern, respect, and consideration?
1. Differential Treatment
[22] The preliminary issue, as stated by Iacobucci J. in Law, supra, is to determine whether the impugned provisions -- clause 118.5(1)(a)(ii.2)(A), subsection 118.6(2) and section 118.9 of the Act -- draw a distinction, on the basis of one or more personal characteristics, between the appellant as the claimant and some other person or group of persons, resulting in unequal treatment. This stage of the inquiry is not concerned with whether the distinction in treatment constitutes discrimination (Law, supra, at p. 552).
[23] In order to answer that question, it is necessary to find the appropriate comparator in identifying differential treatment and the grounds of the distinction. When identifying the relevant comparator, the Supreme Court states, the natural starting point is to consider the claimant's view. It is the claimant who generally chooses the person, group or groups with whom he or she wishes to be compared for the purpose of the discrimination inquiry, thus setting the parameters of the alleged differential treatment that he or she wishes to challenge (Law, at p. 532).
[24] In the present case, the appellant did not indicate any comparator groups. However, as this is an informal proceeding and the appellant is a layperson, it is likely a case where it may be appropriate for a court to provide assistance in defining a comparator group. In Law, Iacobucci J. stated at p. 532:
. . . Clearly a court cannot, ex proprio motu, evaluate a ground of discrimination not pleaded by the parties and in relation to which no evidence has been adduced: see Symes, [[1993] 4 S.C.R. 695] at p. 762. However, within the scope of the ground or grounds pleaded, I would not close the door on the power of a court to refine the comparison presented by the claimant where warranted.
[25] Counsel for the respondent expressed the view in his written submissions that the appellant is challenging clause 118.5(1)(a)(ii.2)(A) and subsection 118.6(2) through section 118.9 of the Act. As the appellant chose to make a claim on his own behalf, the relevant comparator group must thus include those to whom the credit is transferred. In this case, the credit is transferred to the parent. In the respondent's view, the appropriate comparator groups would therefore be, on the one hand, parents who have children under 16 years of age enrolled in a school referred to in sections 118.5 and 118.6 of the Act and who are denied the tuition and education tax credits transferred from their child, and on the other hand, parents who have children over the age of 16 enrolled in such a school and to whom the tax credits are allowed.
[26] This basis of comparison seems reasonable to me.
[27] The respondent admits that the operation of clause 118.5(1)(a)(ii.2)(A) and subsection 118.6(2) creates a differential treatment between those two comparator groups, which could constitute a denial of equal benefit of the law under the first step of the equality analysis.
2. Enumerated or Analogous Grounds
[28] Age is one of the enumerated grounds of discrimination in subsection 15(1) of the Charter. The appellant alleges that he was rendered ineligible for the tuition and education tax credits by virtue of his daughter's age and that the use of age as a distinguishing criterion was discriminatory. The appellant does not base his discrimination claim upon any ground other than age.
[29] The respondent raises the point that being a parent of a child under 16 years of age is not an enumerated ground in subsection 15(1) of the Charter. However, applying the Supreme Court of Canada's reasoning in Benner v. Canada (Secretary of State), [1997] 1 S.C.R. 358, at p. 397, where it was accepted that an individual possesses the necessary standing to raise an issue of discrimination based on the gender of his Canadian parent if his own rights are made dependent on that parent's gender, the respondent is ready to admit that the appellant's claim can reasonably be found to stem from a distinction whose basis is the enumerated ground of age.
[30] In the present case, the appellant claims a credit that has been transferred to him by his daughter through the application of section 118.9 of the Act. As the appellant is the only person designated by his daughter, he becomes the person entitled to claim the credits under sections 118.5 and 118.6 and he is therefore directly concerned by a denial of those credits founded on a distinction made on the basis of age. In other words, the appellant's daughter is involved only insofar as the extent of the appellant's rights is made dependent on the age of his daughter.
[31] It can therefore be said here that the impugned sections of the Act draw a distinction on the basis of age, which is an enumerated ground of discrimination in subsection 15(1) of the Charter.
3. Discrimination
[32] Having found that the appellant was subject to differential treatment based on an enumerated ground, the last issue is to determine whether the impugned provisions of the Act have a purpose or effect that is discriminatory within the meaning of the equality guarantee. In the present case, the question raised is whether the age distinctions drawn by sections 118.5 and 118.6 of the Act impose a disadvantage upon the appellant as the parent of a child of less than 16 years of age in a manner that constitutes discrimination under subsection 15(1) of the Charter.
[33] Iacobucci J. stated in Law, supra, a case dealing with the denial of survivor's benefits under the Canada Pension Plan to a widow under the age of 45, that, relatively speaking, adults under the age of 45 have not been consistently and routinely subjected to the sorts of discrimination faced by some of Canada's discrete and insular minorities (Law, at p. 555). I think the same can be said of parents of children of less than 16 years of age. For this reason, it will be more difficult for the appellant to show that the legislative distinction at issue violates his human dignity. As a matter of fact, the appellant did not bring forward any evidence to that effect. The appellant has not demonstrated that either the purpose or the effect of the impugned legislative provisions violates his human dignity so as to constitute discrimination.
[34] It was said in Thibaudeau v. Canada, [1995] 2 S.C.R. 627, that it is of the very essence of the Income Tax Act to make distinctions so as to generate revenue for the government while equitably reconciling a range of necessarily divergent interests (pp. 676 and 702). Gonthier J. went on to say at p. 676:
. . . In view of this, the right to the equal benefit of the law cannot mean that each taxpayer has an equal right to receive the same amounts, deductions or benefits, but merely a right to be equally governed by the law.
. . .
. . . one should not confuse the concept of fiscal equity, which is concerned with the best distribution of the tax burden in light of the need for revenue, the taxpayers' ability to pay and the economic and social policies of the government, with the concept of the right to equality, which as I shall explain in detail later means that a member of a group shall not be disadvantaged on account of an irrelevant personal characteristic shared by that group.
[35] The tuition and education tax credits concerned in sections 118.5, 118.6 and 118.9 are intended to provide tax relief to students (or to a supporting person) by recognizing the tuition and non-tuition costs they need to incur in order to receive post-secondary education or employability training through a certified institution that teaches occupational skills (see paragraph 7 of the affidavit signed by Donald Phillip Wilson, who holds a position as an economist in the Personal Income Tax Division of the Tax Policy Branch of the Department of Finance, Exhibit R-1).
[36] According to Mr. Wilson, the age 16 criterion is a clear and effective way to limit tax assistance to post-secondary education and occupational training (Exhibit R-1, paragraphs 9 and 15). Indeed, the age of 16 was used in the Act as a cut-off for the tuition and education tax credits in order to be consistent with provincial requirements that every individual receive secondary schooling up to a certain mandatory age (16 in most of Canada's provinces) before continuing on to occupational training or post-secondary education (see Exhibit R-1, paragraphs 10 and 11). In Mr. Wilson's view, the choice of age 16 is therefore reasonable in the context of a broad-based national tax system. (Exhibit R-1, paragraph 21).
[37] It may be that the legislative provisions at issue impose a disadvantage on parents of children of less than 16 years of age who are training to become professional dancers. But it is unlikely to be a substantive disadvantage, viewed in the context of the legislation. In Thibaudeau, supra, Gonthier J. said in relation to the inclusion/deduction system that existed at the time for child support payments (at p. 696):
. . . In the first place, legislation must be assessed in terms of the majority of cases to which it applies. The fact that it may create a disadvantage in certain exceptional cases while benefiting a legitimate group as a whole does not justify the conclusion that it is prejudicial.
I think the same reasoning can apply here.
[38] As Binnie J. said in Granovsky v. Canada (Minister of Employment and Immigration), [2000] 1 S.C.R. 703 at p. 734:
The question therefore is not just whether the appellant has suffered the deprivation of a financial benefit, which he has, but whether the deprivation promotes the view that persons with temporary disabilities are "less capable, or less worthy of recognition or value as human beings or as members of Canadian society, equally deserving of concern, respect, and consideration" (emphasis added).
[39] The differential treatment imposed by the Act does not promote the notion that parents of children under 16 years old are less deserving of concern, respect and consideration. Indeed, as soon as the child attains the age of 16, the tax credits will be available either to the child or to his or her parent, as long as all the other conditions are met. That temporary differential treatment does not foster the view that people in this class are less capable or less worthy of recognition or value as human beings or as members of Canadian society. Given the contemporary and historical context of the differential treatment and those affected by it, the legislation does not stereotype, exclude or devalue parents of children under 16 years of age. The legislation only postpones the right to a tax credit until the child has attained 16 years of age and it does so for the economic purpose of providing tax relief to individuals pursuing post-secondary or occupational training, and for the social purpose of requiring individuals under age 16 to attend primary or secondary school full-time (see Exhibit R-1, paragraphs 20 and 21).
[40] It is appropriate here to cite La Forest J. who, in McKinney v. University of Guelph, [1990] 3 S.C.R. 229, said in relation to age and the allocation of benefits (at p. 297):
The truth is that, while we must guard against laws having an unnecessary deleterious impact on the aged based on inaccurate assumptions about the effects of age on ability, there are often solid grounds for importing benefits on one age group over another in the development of broad social schemes and in allocating benefits.
[41] In such circumstances, where legislation does not demean the dignity of those it excludes in either its purpose or its effects, it is open to the legislature to use age as a "proxy" for long-term need (Law, at p. 560) or, as in the present case, for broad social schemes.
[42] In the circumstances of the present case, recalling the purposes of subsection 15(1) of the Charter, I do not see any violation of human dignity. The impugned distinctions here do not involve the withholding of a government benefit on the basis of stereotypical assumptions about the demographic group of which the appellant happens to be a member. I must therefore conclude that, when considered in the social, political and legal context of the claim, the age distinctions in sections 118.5 and 118.6 of the Act are not discriminatory.
[43] Given the finding that the impugned legislative provisions do not infringe subsection 15(1) of the Charter, it is not necessary to turn to section 1 of the Charter.
[44] In the circumstances, I must therefore dismiss the appeal.
Signed at Ottawa, Canada, this 7th day of February 2002.
|
"Lucie Lamarre" |
J.T.C.C.
COURT FILE NO.: 2001-300(IT)I
STYLE OF CAUSE: William J. Troupe and
Her Majesty The Queen
PLACE OF HEARING: Ottawa, Ontario
DATE OF HEARING: September 11, 2001
REASONS FOR JUDGMENT BY: The Honourable Judge Lucie Lamarre
DATE OF JUDGMENT: February 7, 2002
APPEARANCES:
For the Appellant: The Appellant himself
Counsel for the Respondent: Pascal Tétrault
COUNSEL OF RECORD:
For the Appellant:
Name:
Firm:
For the Respondent: Morris Rosenberg
Deputy Attorney General of Canada
Ottawa, Canada
2001-300(IT)I
BETWEEN:
WILLIAM J. TROUPE,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
Appeal heard on September 11, 2001, at Ottawa, Ontario, by
the Honourable Judge Lucie Lamarre
Appearances
For the Appellant: The Appellant himself
Counsel for the Respondent: Pascal Tétrault
JUDGMENT
The appeal from the assessment made under the Income Tax Act for the 1999 taxation year is dismissed.
Signed at Ottawa, Canada, this 7th day of February 2002.
|
"Lucie Lamarre" |
J.T.C.C.