{'index': 9, 'text': 'For the foregoing reasons, the appeal of the Appellant is allowed and the matter referred back to the Minister for reassessment in accordance with my reasons. More specifically, the Minister shall reassess the Appellant in respect of its 2014 Taxation Year on the basis that:\n\n(a) World Surplus assets in the amounts of $110,116,000 for the 2013 taxation year CIF and $217,025,000 for the 2014 taxation year CIF are not to be included;\n\n(b) assets and liabilities of the A&S Business in the amounts of $982,000 for the 2013 taxation year CIF and ($3,299,000) for the 2014 taxation year CIF are to be included; and\n\n(c) the Appellant is correct in designating Investment Property in respect of its A&S Business pursuant to ITR paragraphs 2401(2)(b) and (d), including, pursuant to ITR paragraph 2401(2)(d), any additional Excess CIF determined in accordance with these reasons.\n\nThe Appellant has 30 days from the date of this decision to provide written submissions on costs, not to exceed 10 pages. The Respondent has a further 30 days to provide written submissions on costs in response to the Appellant’s submissions. Signed at Toronto, this 17th day of August 2023. (Independent Order of Foresters v. The King, https://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/521144/index.do?q=%2217th+day+of+August+2023%22)'}
INSTRUCTIONS: Indicate whether the following judgment excerpt from a Tax Court of Canada decision allows the appeal or dismisses the appeal. Where the result is mixed, indicate that the appeal was allowed. Ignore costs orders. Where the outcome is unclear indicate other.  
Options: allowed, dimissed, other

JUDGMENT EXCERPT: {{text}}
OUTCOME:
INSTRUCTIONS: Indicate whether the following judgment excerpt from a Tax Court of Canada decision allows the appeal or dismisses the appeal. Where the result is mixed, indicate that the appeal was allowed. Ignore costs orders. Where the outcome is unclear indicate other.  
Options: allowed, dimissed, other
The Appellant has 30 days from the date of this decision to provide written submissions on costs, not to exceed 10 pages. The Respondent has a further 30 days to provide written submissions on costs in response to the Appellant’s submissions. Signed at Toronto, this 17th day of August 2023. (Independent Order of Foresters v. The King, https://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/521144/index.do?q=%2217th+day+of+August+2023%22)
OUTCOME: