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Findings The relevant sections to be considered are paragraphs 6(1)(b), 8(1)(h), subsection 8(2) and section 67 of the Income Tax Act, which read as follows: 6.(1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (b) all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer. 8.(1) In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (h) where the taxpayer, in the year, (i) was Ordinarily required to carry on the duties of his employment away from his employer’s place of business or in different places, (ii) under the contract of employment was required to pay the travelling expenses incurred by him in the performance of the duties of his office or employment, and (iii) was not in receipt of an allowance for travelling expenses that was, by virtue of subparagraph 6(1)(b)(v), (vi) or (vii), not included in computing his income and did not claim any deduction for the year under paragraph (e), (f) or (9), amounts expended by him in the year for travelling in the course of his employment. 8.(2) Except as permitted by this section, no deductions shall be made in computing a taxpayer’s income for a taxation year from an office or employment. 67. ...

Mr Balint said he had a similar objective and, in addition, he planned to take space in the proposed building for use in connection with his automotive repair business. ...

For the respondent: —The appellant realized income in the year in the amount of $89,549.63 from the sale of securities; — By a memorandum of agreement (Agreement) dated January 28, 1969, the appellant agreed with Kidd Copper Mines Limited (Kidd) and Sand Bay Investments Limited (Sand Bay) to carry out certain operations with respect to a project known as the Spanish River Mine (Spanish River); — Pursuant to the agreement, Kidd agreed to pay the appellant its operating costs plus equipment rentals plus 10% for overhead profit; —The appellant earned an overhead profit in the amount of $63,110.56 in its 1969 taxation year pursuant to the said memorandum of agreement; —The said profit was not earned by the appellant in connection with the operation of a mine; —The said profit was not earned by the appellant during a period of exemption under subsubsection 83(5) of the pre-1972 Income Tax Act’, —The appellant has knowingly or under circumstances amounting to gross negligence made an omission in a return as a result of which the tax that would have been payable by it for a taxation year, if the tax had been assessed on the basis of the information provided in the return, is less than the tax payable by it for the year. ...

Details were provided by the appellant indicating that at least a total of $2,780.94 had been paid out directly to third parties in connection with the particular residence occupied by Valerie Fowler, owned by the appellant, in this instance Kevin Fowler. ...

I find the borrowing of monies from Dalhousie University has been done in connection with the acquisition of a residence for personal occupation by the appellant and her husband and that interest paid thereon was therefore a personal or living expense within the meaning of paragraph 18(1)(h) of the Act. ...

The issue in this appeal arises from the deductions in his 1973 income tax return of an amount of $1,888.26 claimed by the appellant as a travelling allowance in connection with his employment, which was disallowed by the Minister in his reassessment dated August 6, 1974. ...

The facts of this appeal indicate that the appellant started to write in 1956 for his own amusement and did not until 1969 claim any expenses incurred in connection with his writing. ...

This work, which had no direct connection with his official duties as an RCMP officer, was brought to the attention of the Royal Canadian Mounted Police, which considered this extraordinary performance “beyond what could normally be expected by management” sufficient reason to recommend the appellant for a special award under the Federal Merit Award Programme. ...

First, whether a deduction of $690 claimed by the appellant as expenses incurred in connection with meals and accommodation while travelling in the course of his employment away from his employer’s regular place of business was properly reduced by the Minister of National Revenue to an amount of $255 with respect to such expenses. ...

Therefore I can see no discrimination, nor any direct connection between the two sections. ...