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I am therefore obliged to virtue of subsection 178(2) to order the Minister to pay all reasonable and proper costs of the taxpayer in connection with the appeal and I do so. ...

It should be noted in connection with this purchase option that the sum of $37,500 had to be paid before the option could be exercised by defendant. ...

In this connection Michael Staves, the loan officer of the Royal Bank in charge of the Appellant's account, testified as follows: A. ...

The Minister shall pay to the defendant all his reasonable and proper costs* [6] in connection with this appeal. 1 Actually they withdrew from the partnership to practise elsewhere. ...

He also argued that counsel for the Appellant wrongly confuses "activity" with "purpose" when she argues that the payment of pension benefits is the Appellant's principal activity. [9]      Both parties agree that the "principal activity" cannot simply be derived from the number of employees engaged in one activity, or the number of transactions that take place in connection with one activity. ...

For the purpose of subparagraph (1)(n)(ii), a taxpayer’s scholarship exemption for a taxation year is the total of   (a)  the total of all amounts each of which is the amount included under subparagraph (1)(n)(i) in computing the taxpayer’s income for the taxation year in respect of a scholarship, fellowship or bursary received in connection with the taxpayer’s enrolment   (i)  in an educational program in respect of which an amount may be deducted under subsection 118.6(2) in computing the taxpayer’s tax payable under this Part for the taxation year, for the immediately preceding taxation year or for the following taxation year, or   (ii) in an elementary or secondary school educational program,   [15]          Paragraph 56(1)(n) draws a distinction between payments made in the course of business or employment versus payments made to provide financial assistance to further the recipient’s education. ...

He “habitually or systematically exercised” that business^:. [4] All the fees received in connection with the loans, be they interest, commitment fees, or stand-by fees, are income earned from the money lending business exercised by the plaintiff. ...

With regards to the nature and purpose of the payment, the Court found that it was dictated by business considerations, it was made to satisfy a legal obligation and it could be viewed as a reimbursement of excess compensation received: "[l]t was therefore a payment in connection with a business deal relating to the land trading activities of Shefner and of East End... on the whole of the evidence, Shefner made the payment of $443,000 in the course of his land trading activities and in consequence of his carrying on that type of business. ...

It is of some significance to note in this connection that the lands were entered in the books of the company in an account under the heading “Land for Resale*’. ...

BACKGROUND [3]                No tribunal record was requested in connection with this application for judicial review, and no tribunal record was filed. ...