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Two of the three assessments in question were made on the basis that the person assessed had made a profit from an adventure in the nature of trade in connection with a real estate transaction, and so the profit was from a business and consequently to be included in its income. ... Mr Mann’s evidence was frequently corroborated by copies of correspondence, either to or from him, as well as evidence given by two members of the law firm who acted for him in connection with the negotiations with Park’n Fly and with the Department of Highways. ...

In support of this submission, the defendant first refers to paragraph 12(1)(a) of the Income Tax Act which reads as follows: 12. (1) In computing income, 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 property or a business of the taxpayer, The defendant then refers to paragraph 12(1)(h) of the Act and subparagraph 139(1)(ae)(i) which read as follows: 12. (1) In computing income, no deduction shall be made in respect of (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, 139. (1) In this Act, (ae) “personal or living expenses” include (i) 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, By reference to these sections, the defendant submits that when paragraph 12(1)(a) speaks of profit, it must be read with paragraph 12(1)(h) and subparagraph 139(1)(ae)(i) and when so read is qualified so as to mean “property acquired with a reasonable expectation of profit”. ... It is never necessary to show a causal connection between an expenditure and a receipt. ...

Mr Tilsley testified that when he was doing the work in accordance with the appellant’s instructions he was at all material times on the Howe Company payroll; received most of his instructions from the president, Mr Howe; received reimbursement for travel and other expenses from the Howe Company; did not bill the appellant in his capacity as a geologist or prospector for services rendered and disbursements made in connection with the work; knew nothing of the payment of $750 to Mr Howe by the appellant until well after it had been made and received no funds other than the money involved in obtaining the prospector’s licences from Mr Howe or the appellant. ... This conclusion is, of course, reinforced by the extracts from the accounting records of the Howe Company entered in evidence which, while quite confusing, indicated that the moneys had been accounted for at some time by the company and, further, because in the various expense accounts which were received in evidence Mr Tilsley charged at least some of his expenses in connection with the Cape Breton claims through the Howe Company for the account of the appellant. ...

.): ● the nature of the property sold; ● the length of the period of ownership; ● the frequency or number of similar transactions; ● work expended on or in connection with the property; ● the circumstances that were responsible for the sale of the property; ● motive. [25] The tests are all based on the facts of the particular case and directly or indirectly lead back to the intention of the taxpayer. … [4] If the Appellants were builders within the meaning of section 123 of the Excise Tax Act, they were required to remit GST/HST when they sold the home. ... (d) Work Expended on or in Connection with the Property [31] After moving into Balliol, the Appellants obtained a new home warranty from the Province of Ontario. ...

As will be set forth later herein the appellants attribute the reason for the incorporation of New-West and Save-On and the maintenance of the separate companies to problems and difficulties in connection with the activities and demands of the Amalgamated Meat Cutters Union. ... The appellants attribute the reason for the incorporation of New- West and Save-On to problems in respect of the activities and demands of the Amalgamated Meat Cutters Union, and Mr Wosk testified in that connection. ...

The terms of the agreements, which have significance in connection with the issues in this case, are mentioned in those reasons and need no repetition here. ... In connection with that alternative position I concur in the view of Thurlow, J to the effect that there was nothing to be taken into account as income by the appellant in respect of such amounts in any taxation year earlier than 1966 and I concur in his reasons for that conclusion. ...

The manager shall be reimbursed for all travelling and other expenses actually and properly incurred by him in connection with his duties hereunder. 9. ... In consideration of your co-operation in assisting us in arranging the sale of the business of MD and on condition that MD shall have accepted our offer to purchase rights in the form seen by you and shall enter into the foregoing agreement, we agree to pay to you out of the fee receivable by us in connection with such sale the sum of $20,000.00 plus one- third of the percentage excess fee receivable by us. ...

The developers themselves had apparently only put up $500 of their own money for the option plus whatever other expenses they had incurred in connection with their preliminary plans and negotiations with the lending companies. ... He was not unduly concerned when no building took place during the winter months but in May 1964 he saw a letter from the Public Works Department of the City of St Catharines which indicated that difficulties had arisen in connection with the installation of the sewers and utilities and he was given to understand by the borrowers that these might now cost about $130,000 instead of the $15,000 they had anticipated. ...

Dr Holland testified the structural control in both ore bodies was in a north-south direction and because Jersey lay to the west of East Jersey, there was, in his words, no structural connection between the two ore bodies. ... In this connection, I would refer to what Cartwright, J (as he then was) said in North Bay Mica Co Ltd v MNR, [1958] S.C.R. 597 at 601; [1958] CTC 208 at 212: “For the appellant it is contended that the word ‘mine’ as used in clause (b) of Section 74(1) means not ‘a portion of the earth containing mineral deposits’ but rather ‘a mining concern taken as a whole, comprising mineral deposits, workings, equipment and machinery, capable of producing ore’. ...

In or about 1967, Mr Kirby approached Mr Martin in connection with his financial difficulties. ... (In this connection, useful reference may be had to such cases as Lars Willumsen v MNR, [1968] 2 Ex CR 257, [1967] CTC 13, and Gerard Alain v MNR, [1971] Tax ABC 1100.) ...