Précis: This case involves some ingenious and complex legal argumentation but boils down to the question whether a Tax Court settlement entered into in 2014 between the taxpayer (and many others) and CRA allowed the taxpayer to claim deductions in 1997 and 1998 from a limited partnership of which he was a member but precluded CRA from adding partnership gains to his income during the same period. CRA reassessed the taxpayer adding such gains to his income and the taxpayer appealed the reassessments again to the Tax Court. The 1997 appeal was quashed on consent for a technical deficiency. The 1998 appeal was dismissed on the basis that the settlement agreement permitted CRA to reassess the taxpayer’s 1998 taxation year to include partnership gains in his income. Accordingly the appeal was dismissed with costs.
Savics v. R. – TCC: Settlement agreement precluded the taxpayer from disputing the inclusion of partnership gains in his incomeREAD MORE »