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In light of that conclusion the deductibility of the expenses claimed must depend upon whether the appellant has been able to bring himself within the provisions of subsection 8(1), and specifically paragraph 8(1)(f), which provides a deduction, in computing income from an office or employment, of: 8.(1)(f) Where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer’s place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(l)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (vi) outlays or expenses that would, by virtue of paragraph 18(1)(1), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by him. ... First, the taxpayer must be employed in connection with the selling of property or the negotiation of contracts. ...

The vendors represent and warrant to the purchaser as follows: (j) The company is the owner of all property and assets used by the company in connection with its business, free of all registered liens, charges and encumbrances except liens for current taxes and employee tax deductions referred to in paragraph (I) not yet due and except for any pledges, liens or encumbrances in favour of: I. ... In paragraph 3(j), the vendors have represented and warranted that any pledges, liens and encumbrances in their favour on the property and assets used by the company in connection with its business will be discharged prior to the closing. ...

Even permanency of abode is not essential since a person may be a resident though travelling continuously and in such a case the status may be acquired by a consideration of the connection by reason of birth, marriage or previous long association with one place. ... R. 621 (K.B.), that: To determine whether a person has ceased to be resident of any particular place, the duration of his previous residence, his connections with that community and his interest in it are circumstances to be considered. ...

The term ''personal or living expenses" includes, amongst other things: 248(1)(a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, The issue in Moldowan, supra, was whether a taxpayer's chief source of income was either farming or a combination of farming and some other source. ... The definition of “personal or living expenses" cannot and does not suggest that expenses of property not maintained in connection with a business carried on for profit or with a reasonable expectation of profit are in all circumstances "personal or living expenses". ...

Robert Hokanson says that there was either no seizure, or if there was a seizure, no connection between the seizure of the vehicle and the subsequent payment of the judgment. ... He set a standard that I find easier to apply, being "...a reasonably arguable case for an exercise of judicial discretion increasing the fees of solicitors and counsel in connection with this appeal. ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5. ... I do not find that high degree of negligence in connection with the misstatements of business income. ...

Berube’s testimony concerning his net income for these two years and any connection therewith arising out of the company's affairs. ... He said his wife's earnings were used to pay for all personal, domestic and family matters and that all expenses paid by the company in connection with his automobile use and for promotion and insurance were solely for business purposes. ...

The applicable statutory provisions in this income tax appeal are subsections 9(1), 9(2), 31(1) and 248(1), and paragraphs 18(1)(a) and 18(1)(h) of the Act: 9. (1) Subject to this Part, a taxpayer's income for a taxation year from a business or property is his profit therefrom for the year. (2) Subject to section 31, a taxpayer's loss for a taxation year from a business or property is the amount of his loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source mutatis mutandis. 31.(1) Where a taxpayer's chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income, for the purposes of sections 3 and 111 his loss, if any, for the year from all farming businesses carried on by him shall be deemed to be the aggregate of (a) the lesser of (i) the amount by which the aggregate of his losses for the year, determined without reference to this section and before making any deduction under section 37 or 37.1, from all farming businesses carried on by him exceeds the aggregate of his incomes for the year, so determined from all such businesses, and (ii) $2,500 plus the lesser of (A) 1/2 of the amount by which the amount determined under subparagraph (i) exceeds $2,500, and (B) $2,500, and (b) the amount, if any, by which (i) the amount that would be determined under subparagraph (a)(i) if it were read as though the words "and before making any deduction under section 37 or 37.1” were deleted, exceeds (ii) the amount determined under subparagraph (a)(i); and for the purposes of this Act the amount, if any, by which the amount determined under subparagraph (a)(i) exceeds the amount determined under subparagraph (a)(ii) is the taxpayer's "restricted farm loss" for the year. 18. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (h) personal or living expenses of the taxpayer except travelling expenses (including the entire amount expended for meals and lodging) incurred by the taxpayer while away from home in the course of carrying on his business; 248. (1) In this Act,"business" includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), an adventure or concern in the nature of trade but does not include an office or employment; "personal or living expenses" includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries; The basic issue in this appeal is whether the plaintiff carried on a farming business during his 1977, 1978 and 1979 taxation years with a reasonable expectation of profit. ... See also paragraph 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

For all the above reasons, the appeals in connection with rental losses for the 1984, 1985, 1986, 1987 and 1988 taxation years are dismissed. ... Expenses incurred in connection with travellers cheques amounting to $1,285 were disallowed by Revenue Canada since Dr. ...

MacKay and Keith Eaman were heard on common evidence on May 26, 1989, in the City of Ottawa, Ontario, and the issue is whether the appellants are allowed to deduct capital cost allowance in connection with a yacht in their 1982, 1983 and 1984 taxation years. ... In reassessing the Appellant for the 1982, 1983 and 1984 taxation years, the Respondent disallowed deductions for capital cost allowance in connection with the yacht in the amounts of $21,120.46, $17,465.96 and $19,253.09 respectively. 4. ...