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In this connection, the only actual operation of the mine was in producing a small quantity of coal to consumers in the Village of Ashcroft, B.C. ... There was much correspondence in this connection and from which it was suggested that the inference should be drawn that the Wilson group were trying to get the Hat Creek Mine operating as the mine, In this respect. the letters were written to Powell River Ltd., Pacific Mills Ltd., B.C. ... In this connection, the relevant statute at the material times was the Revised Statutes of British Columbia, 1948, c. 58, the wording of which was carried into Section 23(1) of the 1960 Revised Statutes of British Columbia. ...

The Court has been assisted in coming to a conclusion on the first of these two questions by evidence tendered by the appellant as to (a) the state in which asbestos is found in the ground, (b) the meaning of the expressions “prospecting”, “exploration” and ‘‘development’’ in the jargon of mining engineers and others in the mining industry and the manner in which such operations are carried on in connection with the mineral asbestos, and (c) the manner in which asbestos is mined or extracted. ... Before it was removed, there was no real information as to whether asbestos ore was to be found beneath it in such quantity and quality as to warrant its commercial exploration and the appellant desired the removal of the dump in order to enable it to carry on exploration operations in connection with the area covered by it. ... The difference between the positions taken by the parties in connection with this question has to do with the effect of subsection (5) of Section 83 which provided, in effect, in respect of the years when the expenses in question were incurred, that there shall not be included in computing the income of the appellant ‘‘ income derived from the operation ’ ’ of the new mine. ...

The letter went on to say that “In this connection it should be noted that the $25,000 eliminated from the goodwill valuation may be shown in a ‘Property Acquisition Adjustment’ account.” ... M.N.R., [1957 C.T.C. 146 at 150, 152, that is to say, the advantage of the reputation and connection of the person who had built up the business, that its value is what a purchaser would be willing to pay for the chance of being able to keep the connection of which it consists and that it includes neither a covenant by the vendor not to compete nor a right to the personal services or the business ability of the former proprietor of the business, I find it difficult to conceive of anyone being prepared to pay as much as $57,000 for the opportunity which this business as described presented. ...

The bequest to the charitable organizations was expressly conditioned upon these organizations paying all succession duties and inheritance and death taxes payable in connection with any insurance, gift, or benefit given by the testator in his lifetime or by his will. ... The bequests to the said EAST TORONTO GENERAL HOSPITAL and the FIRST AVENUE BAPTIST CHURCH hereinbefore contained and set forth are absolutely conditional upon both of the said charitable organizations agreeing within the period of six (6) months immediately following my death to pay, and upon each of them paying, respectively, to the complete exoneration of my Trustees and my estate, one-half of all succession duties and inheritance and death taxes, whether imposed by or pursuant to the law of this or any province, state, country, or jurisdiction whatsoever, that may be payable in connection with any insurance on my life or any gift or benefit given by me either in my lifetime or by survivorship or by this my Will or any Codicil thereto, and whether such duties and taxes be payable in respect of estates or interests which fall into possession at my death or at any subsequent time. In the event of the refusal or failure of either or both of the aforementioned charitable organizations to accept and to perform the conditions hereinbefore set out in this paragraph (6)(c) imposed on them, then the bequests in their favour hereinbefore contained and set forth shall lapse and determine absolutely, and my Trustees shall hold and stand possessed of the said Charities Fund upon trust, firstly, to pay out of the said fund all succession duties and inheritance and death taxes whether imposed by or pursuant to the law of this or any province, state, country or jurisdiction whatsoever, that may be payable in connection with any insurance on my life or any gift or benefit given by me either in my lifetime or by survivorship or by this my Will or any Codicil thereto, and whether such duties and taxes be payable in respect of estates or interests which fall into possession at my death or at any subsequent time; and I hereby authorize my Trustees to pay any such duty or tax prior to the due date thereof or to commute the duty or tax on any interest in expectancy; and secondly, to add any balance of the Charities Fund remaining in their hands after making such payments of duties and taxes to the Annuitants Fund as a part thereof and thereafter to deal with the Annuitants Fund as so augmented in the same manner as the said Annuitants Fund is hereinbefore directed to be dealt with in paragraph (6) (b) of this Clause IV of my Will.” ...

And in case the said Arthur Pitman shall at any time be called upon to pay, and shall actually pay any doctors’ bills, hospital bills, medical attendances or any other debt or debts hereinafter incurred by the said Doris Pitman on behalf of herself or of the children, then, and in every such case, the said Arthur Pitman may retain out of the sum payable hereunder, the full amount of such debt together with all expenses incurred by him in connection with the same. ... It was further agreed that the action commenced by the said Doris Pitman against her husband shall be immediately discontinued, the said Doris Pitman agreeing to pay the costs in connection therewith. ... Doris Pitman agreed moreover to immediately discontinue the action commenced by her against the appellant and to pay all costs in connection therewith. ...

He claimed the MacLaren Art Centre was very important to him because he had connections to the person responsible for establishing it, the Gallery was in his hometown, and he had a lifetime appreciation for art. [9] While not much turns on this, I find the Appellant’s claimed interest in assisting the MacLaren Art Centre dubious, and most likely constructed at the time of trial. ... The Amended Loan Application contained revised provisions of the Original Loan Application to, inter alia, remove the loan’s connection to the Ideas donation, which Mr. ... Particularly in 2002, these changes did not eliminate all the references to the connections between Ideas and the loan from Talisker; (iv) The Appellant’s participation was different than other donors. ...

F-7 (A-17-22) brought by the Attorney General of Canada (AGC) in connection with an Order of the Canadian International Trade Tribunal (the Tribunal) issued on December 16, 2021 (AP-2019-047). ... In its request for redetermination, Pier 1 argued that the DVM should not apply in connection with its imported goods. [7] On December 27, 2019, the President of the CBSA rejected Pier 1’s request and accordingly upheld the CBSA’s previous determination with respect to the VFD and the validity of the said DASs. [8] On March 26, 2020, Pier 1 filed an appeal of the President of the CBSA’s re-determination decision before the Tribunal pursuant to subsection 67(1) of the Customs Act. [9] The Tribunal, ruling de novo, issued a decision followed by an order in relation to Pier 1’s appeal. ... Amounts included Montants compris (3) Without limiting the generality of paragraph (2)(a), the costs, charges, expenses and value referred to in that paragraph include: (3) Sont compris parmi les coûts et frais et la valeur mentionnés à l’alinéa (2)a): (a) the costs, charges and expenses referred to in subparagraph 48(5)(a)(ii); a) les coûts et frais visés au sous-alinéa 48(5)a)(ii); (b) the value of any of the goods and services referred to in subparagraph 48(5)(a)(iii), determined and apportioned to the goods being appraised as referred to in that subparagraph, whether or not such goods and services have been supplied free of charge or at a reduced cost; and b) la valeur des marchandises et services visés au sous-alinéa 48(5)a)(iii) déterminée et imputée aux marchandises à apprécier de la manière visée dans ce sous-alinéa, même lorsqu’ils sont fournis sans frais ou à coût réduit; (c) the costs, charges and expenses incurred by the producer in respect of engineering, development work, art work, design work, plans or sketches undertaken in Canada that were supplied, directly or indirectly, by the purchaser of the goods being appraised for use in connection with the production and sale for export of those goods, apportioned to the goods being appraised as referred to in subparagraph 48(5)(a)(iii). c) les coûts et frais, supportés par le producteur, des travaux d’ingénierie, d’étude, d’art, d’esthétique industrielle, de plans ou croquis exécutés au Canada et fournis, directement ou indirectement, par l’acheteur des marchandises à apprécier en vue de leur production et de leur vente à l’exportation, imputés à ces marchandises de la manière visée au sous-alinéa 48(5)a)(iii). ...

However, even with reference to the attached Memorandum, the Reconsideration Panel noted that it was unable to identify the grounds raised in connection with an error of law or an error of fact and also noted that counsel had noted that [translation] “the Appeal Panel erred”. [31] The Reconsideration Panel noted that at the hearing, Mr. ... Kenney had requested, namely, Grade 2; and (3) did not identify anything to support the application in connection with an error of fact. [32] The Reconsideration Panel reiterated the obligations imposed by section 39 of the Appeal Board Act. [33] The Reconsideration Panel then again noted that Mr. ... Kenney does not raise any arguments challenging this finding by the Reconsideration Panel, and on the basis of the evidence, it could reasonably conclude that this ground for reconsideration was not met. [47] Third, in connection with a possible error of law, Mr. ...

Position of the Parties (1) The Appellant [27] The Appellant submits that he was a commissioned employee because he was paid on a per patient visit basis and that he is entitled to deduct the expenses that he claimed for the Taxation Years. [28] With respect to the use of the home office, the percentages on the T2200s issued by the Employers add up to more than 50 percent and therefore the condition in paragraph 8(13)(a) is satisfied. (2) The Respondent [29] The Respondent submits that the Appellant was a salaried employee and denies the Appellant’s entitlement to a deduction of expenses greater than the expenses allowed by the Reassessments. [30] The Appellant was not employed in connection with the selling of property or the negotiation of contracts and therefore the deductions permitted by paragraph 8(1)(f) do not apply to the Appellant. [31] Contrary to the position of the Appellant, the use of a home office must be determined for each office or employment and the percentage of use for each of the three separate employments in issue in these appeals cannot be aggregated. [32] All but one of the T2200s indicates home office use by the Appellant of less than 50 percent and the remaining form indicates home office use of exactly 50 percent in 2015. ... The introductory words of paragraph 8(1)(f) state the following condition that must be met for the paragraph to apply to the Appellant: where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, and … [37] The Appellant is a registered nurse who provides nursing services to patients and who is compensated for those services on a per patient visit basis. ... Accordingly, the Appellant was not entitled to a deduction of motor vehicle expenses incurred in respect of his employment by ParaMed for any of the Taxation Years. [62] The fact that the CRA may have considered a greater per kilometer allowance than that provided by ParaMed reasonable does not entitle the Appellant to deduct the difference under paragraph 8(1)(h.1) when the allowance was not included in income because of subparagraph 6(1)(b)(vii.1) and there is no evidence that the allowance was not reasonable. [17] [63] According to the T2200 forms issued to the Appellant by Spectrum, the motor vehicle allowance provided to the Appellant by Spectrum was not based solely on the number of kilometers driven by the Appellant in connection with his employment by Spectrum. ...

C.R. 77 at 81; [1947] C.T.C. 63, I expressed the opinion that it was not a condition of the deductibility of a disbursement or expense that it should result in any particular income or that any income should be traceable to it and that it was never necessary to show a causal connection between an expenditure and a receipt. ... The discussion of this point in the present case is, in a sense, academic, for even if it were necessary to show a causal connection between an expenditure and income it could be done in the present case. ... Moreover, the connection between the appellant’s gain or production of income from its business and the payments made by it was not remote in any sense of the term. ...