Précis: This was a decision on combined income tax and GST appeals. In the Tax Court Justice Owen found that Mr. Salloum was not engaged in business during the period under appeal and dismissed his appeals. He appealed to the Federal Court of Appeal where his appeals were dismissed from the bench on the basis that the Court could not interfere with Justice Owen’s finding that Mr. Salloum was engaged in “the ‘inherently personal activity’ of getting an education so that, at some future time, he could use that education to pursue a profit.” [Para. 6].
Salloum v. R. - FCA: Taxpayer not engaged in business - appeal dismissedREAD MORE »