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At page 6013, Linden J.A. stated: …] otherwise agree that the Moldowan test should be applied sparingly where a taxpayer’s ‘business judgment’ is involved, where no personal element is in evidence, and where the extent of the deductions claimed are not on their face questionable. ...

. /?. [4] For the purpose of computing her income under section 3 of the Income Tax Act, a taxpayer is entitled to deduct losses which derive from a business or property which is a source of income; in order for a business or property to be a source of income it must either produce a profit, or at least the taxpayer must have a reasonable expectation of profit from it. ...

Canada (Director of Investigation & Research) (1997), 103 O.A.C. 310 (Ont. ...

., granted advances totalling some $63,000 to Cordeau between February and May 1996. (...)? ...

C.A.). 4 [1985] 1 S.C.R. 613 (S.C.C.). 5 ^Reasons for Judgment, at 18. 6 /?. ...

John & Murray Motors Ltd. (1979), 12 B.C.L.R. 155 (B.C. C.A.). I do not understand Revenue Canada to disagree with the proposition that “due diligence” may constitute a defence. ...

Appellant’s counsel referred to Courtney & Fairbairn Ltd. v. Tolaini Brothers (Hotels) Ltd., [1975] 1 All E.R. 716 (Eng. ...

. /?., [1992] 1 S.C.R. 877 (S.C.C.) the Supreme Court of Canada had occasion to consider the situs of unemployment insurance benefits for purposes of the section 87 exemption. ...

In making these assessments the Minister assumed the facts set out in Paragraph 4 of the Reply to the Notice of Appeal, which read as follows: [TRANSLATION] (a) the deduction for contribution to an RRSP in the 1993 taxation year was allowed at the maximum permitted by the Income Tax Act (“the Act”) and was calculated as follows: 1993 taxation year Calculation of 1992 earned income: Income $36,186 Less: union dues (110) Subtotal 36,076 Plus: R.R.Q. disability pension 8,368 farming profit 1,658 Subtotal 46,102 Less: rental loss (1,151) Total 44,951 1993 taxation year Rate x 18% RRSP deductible before adjustment 8,091 Less: 1992 pension adjustment (6,762) Maximum amount deductible for RRSP $ 1,329 in 1993 (b) the deduction for contribution to an RRSP in 1994 taxation year was allowed at the maximum permitted by the Act and was calculated as follows: 1994 taxation year Calculation of 1994 earned income: Income $37,119 Less: union dues (115) Subtotal 37,004 Plus: R.R.Q. disability pension 8,519 Subtotal 45,523 Less: rental loss (903) farming loss (214) Total 44,406 Rate x 18% RRSP deductible before adjustment 7,993 Less: 1993 pension adjustment (6,939) Maximum amount deductible for RRSP $1,054 in 1994 (c) on June 25, 1996 the Minister affirmed the appellant’s income tax assessments for each of the 1993 and 1994 taxation years. ...

The next two items are amounts of $528.00 and $ 1,000.00, supported by cancelled cheques written to J.S. ...