Précis: This is an appeal of a decision blogged earlier on this site. Mr. Lubega-Matovu was, at the date of the hearing, a retired senior auditor with CRA. In 2006, 2007 and 2008 he claimed business and rental losses that essentially reduced his taxable income to nothing. His wife, Ms. Lukwago, claimed a small amount of business income in those years and also claimed losses from businesses carried on with her husband. Mr. Lubega-Matovu had unsuccessfully appealed assessments of his 2004 and 2005 taxation years before Justice Campbell who found no evidence to substantiate his business activities during the course of a 1 day trial. Similarly, Justice Woods found no evidence of business activities during the course of a 5 ½ day trial.
Lubega-Matovu v. R. - FCA: Appeal of unproven losses dismissed, gross negligence penalties sustainedPlus >