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The Queen, 2004 DTC 3066, 2004 TCC 553, aff'd 2006 DTC 6155, 2006 FCA 81-- summary under Paragraph 37(8)(a) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(8)- Paragraph 37(8)(a) The taxpayer, which in its 1995 and 1996 taxation years was acknowledged by the Minister to be engaged in SR&ED in connection with its efforts in developing new products (surimi and tempura) out of silver hake, was found not to be consuming silver hake in SR&ED activities to the extent that the silver hake represented excess fish purchased by it, i.e., fish that was resold at a loss- notwithstanding that the taxpayer effectively was required to purchase all such silver hake in order to encourage the fishing of the silver hake in the first place. ...

Yelle, 2010 DTC 5128 [at at 7083], 2010 ABPC 94-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) time of dealing is relevant time The taxpayer, who was a member of a partnership, was accused of tax evasion under s. 239(1)(a) in connection with capital cost allowance claims made by the partnership on software that it had purchased at an allegedly inflated price from a vendor who was alleged not to deal at arm's length with the partnership. ...

Yelle, 2010 DTC 5128 [at at 7083], 2010 ABPC 94-- summary under Paragraph 69(1)(a) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(a) The taxpayer, who was a member of a partnership, was accused tax evasion under s. 239(1)(a) in connection with capital cost allowance claims made by the partnership on software that it had purchased at an allegedly inflated price from a vendor who was alleged not to deal at arm's length with the partnership. ...

The Minister limited the taxpayer's deductions in connection with the note portion to the amount of licensing revenues ultimately received. ...

The Minister limited the taxpayer's deductions in connection with the note portion to the amount of licensing revenues ultimately received. ...

MNR, 61 DTC 34 (TAB)-- summary under Class 14 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14 In connection with a purchase by the taxpayer from its president and general manager of the insurance business previously carried on by him, the taxpayer acquired the exclusive right to use the name of the business for a period of ten years. ...

The Queen, [2002] GSTC 124 (TCC)-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) white knight costs A Canadian public company ("Nowsco") that was engaged in the provision of oil field services incurred significant fees for services rendered by financial advisors and a law firm in connection with seeking a "white knight" following the commencement of a takeover bid for its shares, as a result of which it was able to secure a higher price for its shares from the original bidder. ...

The frequency of his transactions was not high (approximately 11 purchases during the period), the length of his holdings did not show an intention for a "quick flip", he did not have any special connection with Tee-Com, and it was not unusual for an investor to spend significant time research and monitoring his investment. ...

He also stated (at para. 34): [T]he meal allowances that were included in the appellants' income were paid in connection with the appellants' performance of their duties within the municipality of Saguenay. ...

Where there is credible evidence, as there is here, of actual use and enjoyment by the taxpayer of the contiguous land in connection with her house, and such use and enjoyment is not of an exaggerated or a natural sort, a great deal of weight must be attached to it in assessing whether such use can be reasonably regarded as contributing to the taxpayer's use and enjoyment of his residence. ...