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In 1982 the appellant claimed travel expenses of $4,581 in connection with the Australia trip which were disallowed by the Minister on reassessment. ... The appellant, 95093 Canada Inc., appeals solely in relation to its claim for a deduction in 1982 for travel expenses incurred in connection with the trip to Australia. ... " The finding of both the trial judge ([1986] 2 C.T.C. 251; 86 D.T.C. 6405) and the Court of Appeal was that the expenses were incurred in connection with the acquisition of a capital asset and were therefore expenditures on capital account. ...

A person who is a resident of a Contracting State and carries on activities in the other Contracting State in connection with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated in that other Contracting State shall, subject to paragraph 3 of this Article, be deemed to be carrying on a business in that other Contracting State through a permanent establishment situated therein. [16]     The starting point is therefore the question of whether GONS carried on business in Canada. ... It conceded, however, that if I found GONS did carry on activities in Canada, it was in connection with the exploration or exploitation of the seabed and subsoil and their natural resources. ... Therefore, given there is no issue regarding whether such activities were in connection with the exploration or exploitation of the seabed, Article 27A applies and GONS is deemed to be carrying on business in Canadathrough a permanent establishment, and is therefore subject to tax in Canada. [21]     Issue- Is GONS entitled to the salary and travel and interest expenses it claimed? ...

I find no connection between these two areas. In any event, I note that Winston Blackmore, in cross-examination, was questioned with respect to the wages paid to family members.   ... They provide me with a more complete picture and there is certainly a connection between them.   ... Again there is a connection and continuity between these read-ins.   [16]          In summary, the Appellant’s additional read-ins, numbers 2 and 3, will be allowed into evidence, but number 1 will not be permitted.   ...

”   [4]      In their income tax returns for the 2004 and 2005 taxation years, the Appellants claimed the following rental losses in connection with the apartment in Bosnia:     Loss Claimed on Apartment               2004   2005 Dragica Opacic   $532   $1,862 Milan Opacic   $532   $1,862   [5]      In their income tax returns for the 2004 and 2005 taxation years, the Appellants claimed the following rental losses in connection with the store in Serbia:   Loss Claimed on Store               2004   2005 Dragica Opacic   $946   $1,928 Milan Opacic   $946   $1,928   [6]      In their income tax returns for the 2004 and 2005 taxation years, the Appellants claimed the following business losses in connection with the activities of D-Plus Co.:       2004   2005 Dragica Opacic   $ 5,400   $ 4,998 Milan Opacic   $13,345   $14,256   [7]      By Notices of Reassessment dated November 5, 2007, the Minister of National Revenue (the “Minister”) reassessed the Appellants for the 2004 and 2005 taxation years. ... The Minister also disallowed all of the business losses claimed by the Appellants in connection with D-Plus Co.   ...

  [25]     In connection with the filing for the first period April 1, 2006 to June 30, 2006, the return dated July 19, 2006, and mailed July 20, 2006, shows sales revenue of $69,627 and GST collected or that became collectible of $4,033.36.  ... Clearly there is no evidence that any tax let alone the entire amount of tax was reported in connection with the self-supply of the complex which cost $31,234,103. ...   [26]     In connection with the reporting period of January 1, 2005 to March 31, 2005, the original return was not submitted into evidence. ...

Tobin sought to establish the connection between the expenses and the Business through his own testimony ... Tobin could conveniently and economically use the truck in connection with the Business. ... It is a matter of degree, but in this case, I am not satisfied that the trip had a sufficient business connection to justify a deduction.   ...

He said that he and his wife would have what he called home parties and, in connection with those, he or his wife would buy goods at retail at stores such as Wal-Mart, which is a well known discount vendor in Canada and the US. ... She said that she noted each sale in her book, but she did not bring it to Court, nor was there any evidence of the most elementary recordkeeping in connection with this activity ... Also, he said that there was an interest charge of $980 with vouchers, however, he could not find where the money was borrowed in connection with this business. ...

The leasing arrangement in the agreement provided that the doctors would lease from the corporation the premises used in connection with the operation of an Audiology Clinic, together with all equipment used in connection therewith on a month-to-month basis for the sum of $5,000, payable on the 20 th of each month. ... The Corporation hereby leases the premises used in connection with the operation of an Audiology Clinic to Campbell and Rooney together with all equipment used in connection therewith, on a month to month basis during the term of this agreement for the sum of FIVE THOUSAND ($5,000.00) DOLLARS per month payable on or before the 20th day of each month for the previous month. 2.          ...

Not to recognize the personal benefit derived from such expenditures without establishing any reasonable connection to an income source, shatters any confidence I might otherwise have in the judgment and credibility of the Appellant and her husband in terms of their having established, in claiming expenses, the required connection between the expenditure and an income source. ...   [5]      Even if the family members trusted this loose arrangement of calculating profits in a year, loose connections between expenses and an income source are not sufficient for income tax purposes and the taxpayer's simple assertions that they are, is not sufficient. ... When expenses by their nature overlap with personal expenses, exacting records are required as to their incurrence in relation to the activity and there must be a reasonable connection between the specific expenditure and the income earning process. ...

His definition was:         Goodwill is the benefit and advantage of a good name, reputation and connection of a business. ... Muller & Co.'s Margarine Ltd., [1901] A.C. 217 Lord Lindley commented on the connectivity between the concept of "goodwill" and that of "business as a going concern"; at p.235 he noted:         Goodwill regarded as property has no meaning except in connection with some trade, business, or calling. In that connection I understand the word to include whatever adds value to a business by reason of situation, name and reputation, connection, introduction to old customers, and agreed absence from competition, or any of these things, and there may be others which do not occur to me. ...