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The Queen, 93 DTC 5457, [1993] 2 CTC 266 (FCTD)-- summary under Disposition of Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Disposition of Property no transfer of title or all the incidents of title In connection with the sale of the taxpayer's business to an arm's length corporation, it was agreed that refillable cylinders would be rented by the taxpayer to the purchaser at, what was found on the evidence to be, a market rate of rent, and that over the subsequent five years, 1/5 of the cylinders would be purchased each year by the purchaser for a stipulated amount. ...

Hershfield J. found that the taxpayer did not demonstrate sufficient connection to the reserve for the years in question. ...

In finding that various legal and other fees incurred by the taxpayer in connection with the oppression remedy and various collateral actions were deductible, Archambault T.C.J. noted that the taxpayer's purpose was to receive more income for a relatively short period of time and that in applying for a remedy against oppression, the taxpayer was only exercising its right created by a statute rather than seeking the creation of a new right. ...

After all, the connection of Explanatory Notes with the shape of the proposed legislation is closer than pre-parliamentary aids which in principle are already treated as admissible: see Cross, Statutory Interpretation, 3rd ed (1995), pp 160-161. ...

The funding was received in connection with the enrolment. It was clear that "PSC did not provide the funding to the appellants in a vacuum" (para. 35). ...

This was not... retaining any investment existing at the time of his death, for investment is not a proper term as to monies in trade, and the testator has not used it in any popular sense, because he speaks of investing in connection with securities and does not regard his business as an investment. ...

The underwriting commissions constituted an "outlay or expense" under the definition that was paid for services rendered by the underwriter in connection with pricing, distributing and managing the public issue of its shares, rather than a discount, notwithstanding that there was a firm underwriting. ...

., ticket sales and the sale of food, beverages and souvenirs) in connection with the production of a figure skating show in Canada by Marco. ...

In finding that the liquidating distribution also was a non-arm's length transaction (notwithstanding that the B.C. company statute "did not empower the shareholders, as a body, to dictate action to be taken by the liquidator" (p. 1072), Thurlow J. stated (p. 1072): "The three shareholders, in determining to wind-up the company, had a common purpose to get rid of certain difficulties which were being encountered in connection with the company by winding it up and, at the same time, having a new company take over its undertaking. ...

In computing the loss, the taxpayer deducted from the proceeds of sale of a property amounts paid into court in connection with outstanding liens placed on the property at the time a building was constructed on it, even though the amount remained in court for some time after 1975. ...