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The issue involves certain amounts received by the appellant in 1990 in connection with her employment at a place called Rocky Mountain Bed and Breakfast in the town of Banff, in the Province of Alberta. ... This meant that Tony performed more than 50 per cent of the duties in connection with the bed and breakfast, and so they changed their arrangement. ...

In 1986, the appellant commenced the business of developing prototypes of, subsequently producing, and maintaining, machine tools to be used in connection with computer applications software. ... S.C. 1970-71-72, c. 63) (the"Act") which includes as" personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the tax- pe for his own use and benefit, and not maintained in connection with a ess carried on for profit or with a reasonable expectation of profit. ...

The subject-matter of the realization — In this connection the authors comment: “... property which does not yield to its owner an income or personal enjoyment merely by virtue of its ownership is more likely to have been acquired with the object of a deal than property that does.... ... Supplementary work on or in connection with the property realized — The authors' comments under this heading read: If the property is worked up in any way during the ownership so as to bring it into a more marketable condition; or if any special exertions are made to find or attract purchases, such as the opening of an office or large scale advertising, there is some evidence of dealing. ...

It is not known whether the Judge faced that issue when preparing the decision that issued two months after the hearing. [12] More significantly, however, the Citizenship Judge’s decision refers to several documents that the Judge reviewed in connection with his assessment of whether Mr. ... For example, the typed, transcribed hearing notes state the following: “still has house; owned houses in 2010; still live in on [sic] of these houses; manage houses; still own hotel; owned in 2010; was getting income in 2010; partner manage accounting firm; started early 2000 while still working at CFAO; used identity to start firm; started CFAO as internal auditor…” The Judge mentioned these factors in connection with the credibility concerns outlined in his decision. [24] According to this Court’s case law, there are three separate tests from which a citizenship judge can choose, one of which is quantitative based strictly on the physical presence requirements, while the other two are more qualitative in nature: Miji v Canada (Citizenship and Immigration), 2015 FC 142 [Miji] at para 19. ...

It is argued that the plaintiff's main activity is the provision of services and the production of "goods" in connection therewith is only incidental to the service being provided. ... As counsel for the plaintiff pointed out, under such a regime, a manufacturer or processor of a product (eg. a chemical fertilizer) who also provided a service in connection therewith (eg. spreading the fertilizer for his customers) would be denied the processing tax deduction. ...

Saikely’s evidence was needed, among other things, to show the connection between the moneys from her parents and her husband. ... The lack of precision, the lack of connection, the lack of records, the lack of documentation, the absence of essential witnesses and, quite frankly, the general evasiveness of the appellant's testimony leads this Court to the conclusion that the appellant has not discharged the onus placed upon him. ...

As I understand it, the substantive point being made by counsel is that these appellants should have known at the time the expenditures of some $159,600 had not been made by the corporation filling out the designation, (because there was no such corporation during the period of making such expenditures) and that therefore they were instantly incurring a tax liability in connection therewith for the corporation initially but not for themselves. ... The evidence established that all the amounts stated by the respondent came from business funds, and the use appeared to be in connection with demands of the shareholder Michel Seguin rather than for legitimate business purposes. ...

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. ... The expenses deducted by the plaintiff from farm revenue which caused the losses were not incurred for the purpose of gaining or producing income from a business or property but were the expenses of property maintained by the plaintiff for the use of his family and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

Subsection 18(2) limits the deduction of interest expenses and property taxes incurred in connection with undeveloped land. ... Therefore, the transaction should be treated as an adventure in the nature of trade, and the foreign exchange loss sustained in connection with it should be treated as an income loss. ...

It is in connection with tree farming, however, that the appellants claim the right to deduct their losses under section 31 of the Income Tax Act. ... Wong testified that the Black Gold Tree Farm suffered further losses in subsequent years as follows: 1986 $18,724 1987 22,406 1988 13,500 (approximate) She also listed the following capital outlays in connection with the tree farm: 1979 land $53,900 1980 equipment 12,946 1981 equipment 9,464 1982 equipment and building 29,866 1983 equipment and building 12,955 1984 equipment and fencing 12,500 1985 equipment 4,374 1986 equipment and fencing 7,828 1987 nil 1988 fencing and sprayer 2,000 1989 tractor 18,000 The total of these capital outlays is $163,833. ...