A J Frost:—This is an appeal from a reassessment dated May 20, 1971 in respect of the appellant’s 1969 taxation year. It was heard at Belleville, Ontario on December 14, 1971 by the Tax Appeal Board as it was then constituted.
The question in issue is whether or not the appellant was in the business of farming with a reasonable expectation of profit during the year 1969. The appellant testified that during that year he was carrying on a farm operation and that the main area of the farming operation was a family farm established by his grandfather in the 1800’s. He claimed that he has always carried on the business of farming with a reasonable expectation of profit.
The appellant had a full-time job as a bookkeeper. In addition he did some outside bookkeeping work and prepared income tax returns for clients. From the evidence, it was apparent that his farming activities had virtually come to a stop about 1966. No income was reported in 1969 and no expenses or outlays indicative of normal farming operations were reported. Under the circumstances the only conclusion the Board can draw is that the appellant at the relevant time was no longer in the business of farming with a reasonable expectation of profit. I also find on the basis of the facts adduced that the appellant’s earned income for the 1969 taxation year, within the meaning of paragraph 79B(1)(c) and subsection 32(5) of the Income Tax Act, was $4,331.37.
Appeal dismissed.