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With respect, this is inconsistent with the distinct routes of appeal to the Tax Court from other decisions of the Minister that are set out expressly in the ITA. [66]                          Where Parliament provided for recourse from a ministerial decision to the Tax Court, it did not rely on an implicit connection to the assessment, but rather created an express right to appeal that decision. ... As Dow notes, s. 66 of the former IWTA provided the Exchequer Court “exclusive jurisdiction to hear and determine all questions that may arise in connection with any assessment made under this Act and in delivering judgment may make any order as to payment of any tax, interest or penalty . . . as to the said Court may seem right and proper” (see A.F., at para. 119 (emphasis added)). ...

T he findings of fact of the Tax Court of Canada judge disclose no such connections in this case.  ... That symmetry was found in Williams to strengthen the connection between the place of employment and the benefits. ... I‑5  , to apply to an Indian’s personal property, the property must have concrete and discernible connections with a reserve. [35]                           In the instant case, the findings of fact of the Tax Court of Canada judge disclose no such concrete connections.  ...

The said words “cost of prosecution” which the “Government bears” are necessarily referable to cost specially incurred in connection with the proceeding it has instituted. ... When acting in the premises, said magistrate and prosecuting officer (who receive their remuneration annually as aforesaid) are doing so merely as part of their regular duties; they were not paid specifically in connection with the prosecution in question. ... [Page 410] The order in council states in terms that “no disbursements in connection with the said prosecution have been made by the Province of Nova Scotia or by the municipality of the county of Halifax.” ...

ON APPEAL FROM THE EXCHEQUER COURT OF CANADA Income tax—Deductions in computing income—Legal expenses incurred in defending suit against using certain words in connection with sale of products—Income War Tax Act, R.S.C. 1921, c. 97, s. 6 (a) (b). ... In the present case it was held that legal fees and expenses incurred by respondent in successfully defending a suit for an injunction against alleged infringement of registered trade marks by using certain words in connection with the sale of respondent's products, fell within that general rule; in that suit the question in issue was whether or not said trade marks were valid, and the right upon which respondent relied was not a right of property, or an exclusive right of any description, but the right (in common with all other members of the public) to describe its goods in the manner in which it was describing them. ... APPEAL by the Minister of National Revenue from the judgment of Maclean J., late President of the Exchequer Court of Canada [1], allowing the appeal of The Kellogg Company of Canada, Limited, the present respondent, from the decision of the Minister of National Revenue affirming certain assessments against said company for income tax under the Income War Tax Act, R.S.C. 1927, c. 97, which assessments disallowed as deductions, in computing the company's income, the amounts of legal fees and expenses incurred in defending a suit brought against it in which there was claimed an injunction to restrain an alleged infringement of registered trade marks by the present respondent's use of certain words in connection with the sale of some of its products. ...

It was this connection that was concrete (see also, on identifying a concrete connection:  McDiarmid Lumber Ltd. v. ... As a result, he was unable to establish a connection with the reserve.  ... There was no connection with the economic development of the reserve.  ...

There is no connection between the two buildings except by a small pipe tunnel which passes under Housey street for housing pipes and wires for conveying steam heat, water, electricity and gas from the first mentioned to the last mentioned building. ... The amendment of 1933, (cc), increased the rate of assessment from 25 to 75 per centum on every person, such as the appellant, carrying on the business of selling or distributing goods, wares and merchandise to a chain of more than five retail stores or shops in Ontario, directly or indirectly, owned, controlled or operated by such person, but the assessment at the increased rate applies only to ‘‘the assessed value of the land occupied or used by him in such business for a distribution premises, storage or warehouse for such goods, wares and merchandise, or for an office used in connection with the said business”. ... It is not suggested, of course, that the land or building was used for "‘storage’’ or ‘‘warehouse’’ for the appellant’s "goods, wares and merchandise” or for ‘‘an office’’ in connection with its business, but it is contended by counsel for the respondent that the land is occupied or used by the appellant in its business for distributive purposes in the sense that the two adjacent buildings taken together are in fact occupied and used by the appellant in its business for the storage and distribution of its goods, wares and merchandise. ...

“To pay out of the capital of the residue of my estate my just debts, funeral and testamentary expenses and all estate, legacy, succession and inheritance taxes or duties, whether imposed by or pursuant to the law of any domestic or foreign jurisdiction whatsoever, that may be payable by any beneficiary of this my Will or any Codicil hereto in connection with the property passing (or deemed to pass by any governing law) on my death...” 2. ... I GIVE, DEVISE AND BEQUEATH the whole of my property of every nature and kind and wheresoever situate including any property over which I may have any general power of appointment to my said Trustees upon the following trusts, namely: a) To pay out of the capital of the residue of my estate my just debts, funeral and testamentary expenses and all estate, legacy, suecession and inheritance taxes or duties, whether imposed by or pursuant to the law of any domestic or foreign jurisdiction whatsoever, that may be payable by any beneficiary of this my Will or any Codicil hereto in connection with the property passing (or deemed to pass by any governing law) on my death or in connection with any insurance and/or annuities on my life or in connection with any insurance and/or annuities on my life or in connection with any gift or benefit given or provided by me either in my lifetime to or for any such beneficiary, or by survivorship,. or by this my Will or any Codicil thereto, or to or for the benefit of any beneficiary of any trust or settlement created by me during my lifetime, and whether such taxes and duties be payable in respect of estates or interests which fall into possession at my death or at any subsequent time; and I hereby authorize my Trustees to commute or prepay any such taxes or duties. ...

Sympathetic though one is inclined to be to the appellant’s plight, the Statutory provisions above-mentioned for non-disclosure, in connection with any legal proceedings of a civil character, do not give any power to a Court to qualify them, nor do the exceptions set out in paragraph 241(4)(c) assist the appellant. ...

Tires and Tubes: (iii) Tires in whole or in part of rubber for automotive vehicles of all kinds, including trailers or other wheeled attachments used in connection with any of the said vehicles—two cents per pounds.”’ ... The point for determination in connection with the claim for excise tax is a little different from that involved in the question of the liability for sales tax. ...

Sympathetic though one is inclined to be to the appellant’s plight, the statutory provisions above-mentioned for non-disclosure, in connection with any legal proceedings of a civil character, do not give any power to a court to qualify them, nor do the exceptions set out in s. 241(4)(c) assist the appellant. ...