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Provided, however, on the resale of such shares, in the event of default, then any surplus over the sum then due from the purchaser or purchasers of such shares under subparagraph (a) hereof, after deducting all costs and expenses incurred in connection with obtaining delivery of such shares and the resale of same, shall be paid to the said purchaser or purchasers of such shares. 6. In connection with the Company’s operations it is agreed by and between the Shareholders as follows: (a) Any party resigning from or being dismissed from the Company (other than dismissal for cause) shall receive, by way of severance pay in complete settlement of all claims he may have against the Company, the amount of the book value of his shares as of date of resignation or dismissal and such amount shall be paid without interest in the manner set forth in sub-paragraph 3(b) hereof; any party dismissed for cause shall have no claim or cause of action against the Company or the remaining Shareholders save and except the payment provided for in paragraph 2(iii) hereof. ... In connection with the Company’s operations it is agreed by and between the Shareholders as follows: (c) In the event of disability preventing normal duties, a Shareholder shall be entitled to the difference between any disability insurance income provided by the Company and his normal salary for a maximum period of six (6) months. ...

Mr Leier stated that the time devoted by J P to work in connection with the leases averages about one hour per month or twelve hours per year. ... These are examples of services rendered by JP P in connection with the leases. The activities of J JP in connection with the leases must be treated, in so far as these cases are concerned, as activities of King George. ...

However, the appellant admitted that among the documents received in connection with the adoption of this first child was a detailed statement of the costs incurred by Cathwel for the mother and the child; this document was entitled “Expenditures”. [2] Listed in the document were the costs for prenatal care, for the delivery and for postnatal care. ... The appellant testified that, in connection with this adoption, he did not receive a document from Cathwel itemizing expenses as had been the case in 1991 when the first child was adopted. ... Brunelle explained it as follows: [TRANSLATION] The letters were addressed to the Jesuits because that was the connection we had between Quebec and Sister Rosa, it was the route that we knew, because, among other things, when my sister-in-law, who is my daughter’s godmother and who went to get her over there, she went to the Jesuits because she had a friend in common which Father Aubin, and she went to mass over there with Sister Rosa; also the building in which Cathwel is located belongs to the Jesuits. ...

‘Tangibles’5 [5] means all of the Vendor’s right, title, estate and interest in and to all tangible depreciable property and assets (except casing) situate in, on or about the Lands, appurtenant thereto or used in connection therewith and with production operations thereon including, but not in limitation of the generality of the foregoing, appurtenant to or used in connection with all producing or shut-in wells located on the Lands. 15 January 1986 (D) Lone Rock and all of its shareholders enter into a share purchase agreement with the appellant whereby the latter acquired all of the shares of Lone Rock. ... Subparagraph 66(15)(c)(iii) reads: (iii) any oil or gas well in Canada or any real property in Canada the principal value of which depends upon its petroleum or natural gas content (but not including any depreciable property used or to be used in connection with the extraction or removal of petroleum or natural gas therefrom). 29 September 1986 (E) Lone Rock as transferor and the appellant as transferee enter into a “Distribution Agreement” whereby Lone Rock “assigns, transfers and conveys to and sets over unto the transferee all of the right, title and interest of the transferor in and to all its property, assets and business”. ...

Nevertheless, a rational connection must exist between the information sought and the administration and enforcement of the ITA. [6] The information sought in the AER Letters is rationally connected to the audits of Dr. ... Nevertheless, a rational connection must exist between the information sought and the administration and enforcement of the ITA (Saipem at paras 25-26). [24] The auditor’s notes indicate that, based on the minute book information provided by the Taxpayers’ accountant, the CRA was interested in obtaining documents pertaining to COG Ltd from 1996 onwards. ... Friedman personally, but also sought documentation pertaining to “entities with which [they] had a connection or affiliation” during the taxation years in question. ...

.; (1) Pied-Mont Dora Inc. is the owner of the trademarks used in connection with the above-mentioned flavour crystals; (j) Net income generated by the appellant’s crystals business was $185,184, $147,249 and $121,102 for taxation years 1991, 1992 and 1993 respectively; (k) Net losses incurred in the racehorse business and claimed by the appellant were $160,750, $70,522 and $193,229 for taxation years 1991, 1992 and 1993 respectively; (1) The appellant deducted the losses suffered in the racehorse business from the income generated by the sale of crystals; (m) The operation of the appellant’s racehorse business from July 1, 1989 to December 31, 1993 never generated any profits; rather it generated operating losses of about $651,195: (n) In the years at issue, the appellant’s chief source of income was neither a farming activity nor a combination of farming and some other source. ... I quote from pages 486 to 489: There has been difference of opinion on whether the word “combination” in s. 13(1) requires some “connection” by way of physical relationship or integration or inter-connection between farming and the subordinate activity which provides another source of income.... ...

The Respondent submits that the income derived by the Appellant from the lease of certain lands is not income incidental to certain farming activities, but rather is income which is derived from a separate and distinct source of income pursuant to Section 4 of the Income Tax Act, SC 1970-71-72 with respect to the 1972 taxation year, and Section 139(1)(a) of the Income Tax Act, RSC 1952, Chapter 148 in connection with the 1971 taxation year. 5. The Respondent states that the disallowance of certain deductions claimed by the Appellant as expenses in the 1971 and 1972 taxation years, was proper on the basis the farming activities were not carried on in the manner of a business carried on for a profit, or with a reasonable expectation of a profit; and on the ground that since these expenses were incurred by the Appellant in his participation in farming activities of a sporting, or hobby nature for his own benefit, they were personal or living expenses within the meaning of Subsection 139(1), and therefore were not deductible under Section 12 of the Income Tax Act, 1952, Chapter 148 as amended, in connection with the 1971 taxation year or, within the meaning of Subsection 248(1), and therefore were not deductible under Paragraph 18(1)(h) of the Income Tax Act, SC 1970-71-72, Chapter 63 as amended. ... The purpose for which the lands were leased and the type of work executed in connection with the leased lands were quite different from the appellant’s farming activities and thus the rental income derived therefrom cannot be considered as an integral part of the appellant’s farm income. ...

Unfortunate as the circumstances may have been, I only can regard him as being the author of his own difficulty in this connection and hold, therefore, that the substantial discrepancies resulting from his calculations were such as to merit the imposition of a penalty by the respondent. ... The word “offence” is used above in connection with the term “gross negligence” in the sense of a breach of law, duty, propriety or misdemeanour, which are several of the meanings of the word “offence” contained in the Shorter Oxford English Dictionary, but I hasten to add that under the Act there is, undoubtedly, a very wide gap indeed between ordinary negligence and “gross negligence”. ... The expression “human error” is ordinarily used in connection with a situation where a person has done something in error or mistakenly, for example, where he has committed an error or mistake in judgment in an emergency, but that expression is not appropriate, in my view, to the present situation where there has, obviously, been a continuing pattern of carelessness or negligence on the part of the appellant commencing in or about the year 1964. ...

I think it useful to set out subsection (1) as well as subsection (2): 44. (1) A deduction from, or refund of, any of the taxes imposed by this Act may be granted (a) where an overpayment has been made by the taxpayer; (b) where a refund or adjustment has been made to the taxpayer by a licensed air carrier under Part Il for the taxes collected or paid on any transportation of a person by air that has not been provided or only partially provided by the air carrier or that has been collected in error by the air carrier; (c) where the tax was paid in error; (d) where the original sale or importation was subject to tax, but exemption is provided on subsequent sale by this Act; (e) where goods are exported, under regulations prescribed by the Minister: or (f) where, due to changes in statutory rates of tax or for other reasons, stamps are returned for exchange. (2) Where goods have been purchased by Her Majesty in right of any province of Canada for any purpose other than (a) resale; (b) use by any board, commission, railway, public utility, university, manufactory, company or agency owned, controlled or operated by the government of the province or under the authority of the legislature or the lieutenant governor in council; or (c) use by Her Majesty or by Her agents or servants in connection with the manufacture or production of goods or use for other commercial or mercantile purposes; a refund of taxes paid under Part III, IV or V may be granted to Her Majesty or to the manufacturer, producer, wholesaler, jobber or other dealer as the case may require. ... It was further admitted the goods in question were not used by the provincial Crown in connection with the manufacture or production of goods. ... He manufacturers his lumber for sale, and, as a general rule, would not manufacture any specific lumber for use in connection with his building contracts, but would simply take lumber for these purposes from the general stock manufactured for sale, and might thus, under the view taken in the court below, escape taxation on all lumber thus diverted from the general stock manufactured for sale. ...

Contentions The position of the appellant was that no amount was received in 1968 or in any other year in connection with the purchase of the property which could be classified as interest income; and that, with regard to the sale of parcel 3, the gain therefrom was on capital account, resulting from the acquisition and sale of capital assets. ... Mr Morton Greenglass, called for the appellant, had provided legal advice and services to the appellant in connection with the mortgage foreclosure and the defence against such foreclosure raised by Clearstream. ... In addition to the security for the loan, noted earlier, Bailey had accepted on behalf of Greenington a 12 /2% interest in the voting stock of Clearstream, certain positions on the board of directors, and he had acted on a building committee in connection with the construction contracts for the golf club grounds and facilities. ...