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Federal Court of Appeal· 2001

Shery v. Canada

2001 FCA 61
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Shery v. Canada Court (s) Database Federal Court of Appeal Decisions Date 2001-03-14 Neutral citation 2001 FCA 61 File numbers A-492-99 Decision Content Date: 20010314 Docket: A-492-99 Neutral citation: 2001 FCA 61 CORAM: ROTHSTEIN J.A. SHARLOW J.A. MALONE J.A. BETWEEN: DOLORES SHERRY Appellant - and - HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, Wednesday, March 14, 2001 Judgment delivered from the Bench at Toronto, Ontario, on Wednesday, March 14, 2001 REASONS FOR JUDGMENT OF THE COURT BY: SHARLOW J.A. Date: 20010314 Docket: A-492-99 Neutral citation: 2001 FCA 61 CORAM: ROTHSTEIN J.A. SHARLOW J.A. MALONE J.A. BETWEEN: DOLORES SHERRY Appellant - and - HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario on Wednesday, March 14, 2001) SHARLOW J.A. _. This is an appeal from the decision of a Tax Court Judge that certain rental losses claimed by the Appellant in 1989, 1990, 1991, 1992, 1993 and 1994 were not deductible because there was no reasonable expectation of profit. The properties were highly leveraged so that most of the losses were the result of interest costs far in excess of rents. Before the Tax Court Judge, the Appellant attempted to explain why the rents were lower than she had anticipated, but he found that her explanations were unsubstantiated. Given the record before the Tax Court Judge, we are unable to conclude that he erred in law. For that reason, this appeal must be dismissed. "Karen…

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Shery v. Canada
Court (s) Database
Federal Court of Appeal Decisions
Date
2001-03-14
Neutral citation
2001 FCA 61
File numbers
A-492-99
Decision Content
Date: 20010314
Docket: A-492-99
Neutral citation: 2001 FCA 61
CORAM: ROTHSTEIN J.A.
SHARLOW J.A.
MALONE J.A.
BETWEEN:
DOLORES SHERRY
Appellant
- and -
HER MAJESTY THE QUEEN
Respondent
Heard at Toronto, Ontario, Wednesday, March 14, 2001
Judgment delivered from the Bench at Toronto, Ontario,
on Wednesday, March 14, 2001
REASONS FOR JUDGMENT OF THE COURT BY: SHARLOW J.A.
Date: 20010314
Docket: A-492-99
Neutral citation: 2001 FCA 61
CORAM: ROTHSTEIN J.A.
SHARLOW J.A.
MALONE J.A.
BETWEEN:
DOLORES SHERRY
Appellant
- and -
HER MAJESTY THE QUEEN
Respondent
REASONS FOR JUDGMENT OF THE COURT
(Delivered from the Bench at Toronto, Ontario
on Wednesday, March 14, 2001)
SHARLOW J.A.
_. This is an appeal from the decision of a Tax Court Judge that certain rental losses claimed by the Appellant in 1989, 1990, 1991, 1992, 1993 and 1994 were not deductible because there was no reasonable expectation of profit. The properties were highly leveraged so that most of the losses were the result of interest costs far in excess of rents. Before the Tax Court Judge, the Appellant attempted to explain why the rents were lower than she had anticipated, but he found that her explanations were unsubstantiated. Given the record before the Tax Court Judge, we are unable to conclude that he erred in law. For that reason, this appeal must be dismissed.
"Karen R. Sharlow"
J.A.
FEDERAL COURT OF CANADA
Names of Counsel and Solicitors of Record
DOCKET: A-492-99
STYLE OF CAUSE: DOLORES SHERRY
Appellant
- and -
HER MAJESTY THE QUEEN
Respondent
DATE OF HEARING: WEDNESDAY, MARCH 14, 2001
PLACE OF HEARING: TORONTO, ONTARIO
REASONS FOR JUDGMENT
OF THE COURT BY: SHARLOW J.A.
Delivered from the Bench at Toronto, Ontario on Wednesday, March 14, 2001
APPEARANCES BY: Ms. Dolores Sherry
For the Appellant on her own behalf
Ms. Carol Calabrese
For the Respondent
SOLICITORS OF RECORD: Dolores Sherry
151 Glendonwynne Road
Toronto, Ontario
M6P 3E8
For the Appellant on her own behalf
Morris Rosenberg
Deputy Attorney General of Canada
For the Respondent
FEDERAL COURT OF APPEAL
Date: 20010314
Docket: A-492-99
BETWEEN:
DOLORES SHERRY
Appellant
- and -
HER MAJESTY THE QUEEN
Respondent
REASONS FOR JUDGMENT
OF THE COURT

Source: decisions.fca-caf.gc.ca

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