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The Tax Court held that the appellant’s medical practice, not her farm, was her chief source of income in 2014 and 2015, so farm losses were limited under subsection 31(1).
The appeal is allowed because the Respondent’s Reply contained assumptions of mixed fact and law (not permitted); therefore no valid factual assumptions were in issue, the burden of proof reverted to the Minister to adduce evidence that the footwear were not zero‑rated, and the Minister failed to lead sufficient evidence to meet that burden.
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