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The factual situation is simple — the appellant’s wife applied for UIC benefits, the application was approved by UIC, and payments resulting from that application and approval were received. ...

For example, in Day & Ross Limited v The Queen, [1976] CTC 707; 76 DTC 6433, the Federal Court held fines paid by a trucking company for violations of highway traffic and weight restriction laws met the purpose test imposed by paragraph 12(1)(a) of the former Income Tax Act. ...

Section 56 of the Act states the following: Amounts to be included in income for year (1) Without restricting the generality of section 3, there shall be included in computing the income of a taxpayer for a taxation year Thus the amount $5,170.99 was received in 1978 and should have been included in income for that year; paragraph 56(1)(h) of the Act reads as follows: Registered retirement savings plan, etc — amounts required by section 146 in respect of a registered retirement savings plan or a registered retirement income fund to be included in computing the taxpayer’s income for the year. ...

By letter of October 20, 1979, the appellant requested that the Minister of National Revenue adjust his 1978 tax return to allow the deduction from the appellant’s employment income unreported business expenses in the amount of $1,599 — there being no income from the appellant’s business in 1978. ...

In this regard reference may be made to MNR v O/va Diana Eldridge, [1964] CTC 545; 64 DTC 5338, and to Day & Ross Limited v The Queen, [1976] CTC 707; 76 DTC 6433. ...

. — any amount required by subdivision k to be included in computing the income of the taxpayer for the year except any amount deemed by that subdivision to be a taxable capital gain of the taxpayer. ...

I would merely note that the matter at issue there was whether or not a benefit had been received by the appellant — not whether an allowance had been received by the appellant. ...

It would appear to me that a taxpayer does not graduate from a business operation (farming — no matter how restricted) to research, based solely upon losses incurred. ...

Generally speaking, damages arise from the failure of a person in fulfilling specific obligations contained in a written or verbal contract; the law; tacit agreements and even in the principles of natural justice — which failure must be the identifiable cause of damages sustained by the other contracting party because of the contravention of his acquired rights. ...

This was calculated as follows: The calculation was made as follows: Cash Value at Maturity $3,397.00 Plus Bonus Additions 867.77 $4,264.77 Cash Value of basic policy at August 5, 1970 $2,055.19 Cash Value of bonus additions at August 5, 1970 356.00 Premiums paid on and after August 5, 1970 6 x $158.54 951.24 3,362.42 Taxable policy gain as reported $ 902.34 In assessing the appellant, the respondent relied, inter alia, on paragraph 56(1)(k), subsections 148(1), (8) and paragraph (9)(f) of the Income Tax Act, SC 1970-71-72, c 63, as amended. ...