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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 was dismissed because the Tax Court correctly applied Moldowan and found the appellant's forestry operations did not constitute his chief source of income due to lack of present and future profitability; the Minister validly reassessed 1993 under s.152(4) because the appellant was careless in failing to reconcile RAMQ statements and had admitted receipt of the amount; the Charter challenge was not considered because it was not raised below and lacked evidentiary basis.
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