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TCC

Aubé v. The Queen, docket 2001-1879-GST-I (Informal Procedure)

It had been determined therein by means of the net worth method that the appellant had a tax liability of $1,260.36 under the Goods and Services Tax ("GST") system in connection with his business's unreported sales. [2]      On the day of the hearing, counsel for the respondent informed the Court that the amount was now reduced to $244.97. ... Therefore, the personal expenses were not recorded twice. [5]      Although the appellant stated that there were a number of errors in the statement of net worth, it seems that those errors had been corrected by the respondent in arriving at a final figure of $244.97 as the tax payable in connection with the business's unreported sales. ... The amount of the tax liability under the GST system for the period from January 1, 1994, to December 31, 1996, in connection with the understated sales of the appellant's business is therefore $244.97. ...
TCC

Ware v. The Queen, 2006 TCC 544 (Informal Procedure)

Ware, however, falls far short of establishing that the expenses claimed were incurred at all let alone that they were incurred in connection with her businesses. [7]      It is not in dispute that Mrs. ... The Minister did allow some of the expenses claimed and these are set out in the schedules to the Reply. [8]      Because of a number of unfortunate and tragic circumstances, none of the businesses succeeded. [9]      The question is whether the appellant has established that the expenses claimed were incurred and that they were incurred in connection with these businesses. [10]     The expenses claimed were for items such as advertising, interest, motor vehicle, maintenance and repairs, office, supplies, legal and accounting, telephone and utilities and rent. ... Ware something on account of rent and utilities in connection with Trafalgar Hall. ...
TCC

Kaupas v. The Queen, 2003 TCC 808

Kaupas was one of over 400 individuals who claimed tax refunds in connection with a fraudulent scheme instigated by Mr. ... Butt was convicted of tax evasion in connection with these transactions and sentenced to three years in penitentiary. ... Butt in connection with this scheme. [3]      This appeal concerns deductions claimed by Mr. ...
TCC

Access Post Production Audio Inc. v. M.N.R., docket 1999-4208-EI

Profit and loss [6] Grosicki bore no expenses in connection with his work. ... I am satisfied on a balance of probabilities that Grosicki had to perform his services personally, and therefore had no chance of profit and risk of loss in connection therewith. ... He had no expenses in connection with his work, did not have printed advertising material or characterize his income as business income for income tax purposes, and exhibited none of the many other attributes of a business. ...
TCC

Phyllis Perlman v. Minister of National Revenue, [1985] 1 CTC 2032, 85 DTC 46

. — In July of 1976, serious problems developed in connection with the Queenscourt mortgage loan and interest payments were discontinued. — On my Income Tax Return for 1978, I claimed a Reserve for Doubtful Debts in the amount of $5,681.71, in connection with my business as a money lender. — Since I was engaged in the business of money lending and was not engaged in any other business in the taxation year, and one of my mortgage loans was in serious default during the year, I believe that I am entitled to claim a Reserve for Doubtful Debts in the amount of 25% of the monies which I advanced on that loan being a reasonable business estimate of the potential loss during that period, pursuant to subsection 20(l)(l)(ii) of the Income Tax Act. ... A document of “trust”, between Lokash, supra, and the appellant indicated the original $25,000 loan at issue had been part of a larger second mortgage totalling about $7 million to Queenscourt, in connection with real estate development and construction. ...
TCC

Burpee Finniss v. Minister of National Revenue, [1984] CTC 2826, 84 DTC 1712

The Minister of National Revenue has disallowed the deduction of the ssaid farming losses, upon the bases that: (a) the expenses giving rise to the said losses were personal or living expenses, and, (b) the losses did not arise in connection with a business carried on for profit or with a reasonable expectation of profit. 5. He submits that the Appellant’s claim for the deduction of farming losses were properly disallowed upon the basis that the expenses giving rise to the said losses were personal or living expenses, and the losses did not arise in connection with a business carried on for profit or with a reasonable expectation of profit. 6. ... While appreciating that none of the above is alone determination of the issues, viewed collectively it can be fairly said that this appellant was not a hobby farmer but rather, during the 1978, 1979 and 1980 taxation years, he has established that the losses arose in connection with farming carried on by him as a sideline business for profit or with a reasonable expectation of profit. ...
ONHCJ decision

Re Schiff, [1949] CTC 97

Clause 1 is the ordinary revocation clause; cl. 2 appoints the executor; cl. 3 reads as follows: “I Direct all my just debts, funeral and testamentary expenses and all succession duties and inheritance and death taxes that may be payable in connection with any insurance or any gift or benefit given by me to any person, either in my lifetime or by this my Will or any Codicil thereto, to be paid and satisfied by my Executors hereinbetore named, as soon as conveniently may be after my decease.’’ Clause 6 reads as follows: “I Declare that an Executor or Trustee, being a solicitor, may be so employed, and shall be entitled to charge and be paid all professional or other charges for any business or act done by him or his firm in connection with the trusts, including any act which an Executor or Trustee, not being a solicitor, could have done personally.” ... (c):‘To pay my just debts funeral and testamentary expenses and all succession duties and inheritance and death taxes that may be payable in connection with any insurance or any gift or benefit given by me to any person either in my lifetime or by survivorship or by this my will or by any codicil hereto/ ‘ The present will contains merely a direction and no such trust, but, it will be observed, the assets of the deceased herein are capable of easy administration and no trust would be required. ...
TCC

Hawrish v. The Queen, docket 95-1271-IT-G

In this connection, the Appellant stated that he paid CIBC by way of a bank draft that he gave to the bank’s lawyers. ... In this connection, I find it useful to refer to the decision of the Supreme Court of Canada in the case M.N.R. v. ... Halyk of the firm of Halyk Dovell represented the Appellant in connection with both matters. ...
EC decision

Robert B. Curran v. Minister of National Revenue, [1957] CTC 384, 57 DTC 1270

This amount never was disbursed by either of the three companies with which Curran had business connections during 1951. ... Brown’s only object was the enlistment for his companies of Curran’s reputed experience, capabilities and connections. ... The appellant predicated his first line of attack on a total lack of employer-employee connection between himself and Brown. ...
SCC

Bastien Estate v. Canada, 2011 DTC 5118 [at at 6014], 2011 SCC 38, [2011] 2 SCR 710

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.  ...

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