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FCTD

Madronich v. The Queen, 89 DTC 5093, [1989] 1 CTC 247 (FCTD)

Paragraph 248(1)(a) describes personal or living expenses as follows: 248. (1) In this Act, "personal or living expenses" includes (a) 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, Considering the evidence in its entirety, I find that the plaintiff's tree farm operation on the Orangeville property was a sideline business for which there was a reasonable expectation of profit realization in the future. ...
FCTD

Karben Holding Ltd. v. The Queen, 89 DTC 5413, [1989] 2 CTC 145 (FCTD)

In addition, as part of the notices of assessment, the Minister refused to allow the deduction of automobile expenses including capital cost allowances claimed, and also disallowed the costs incurred by the plaintiff in connection with foreign exchange and alleged to constitute losses incurred as part of the investment activities of the plaintiff. ...
FCTD

Coupland v. The Queen, [1988] 1 CTC 414, 88 DTC 6252 (FCTD)

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. ...
FCA

Hutterian Brethren Church of Wilson v. The Queen, 79 DTC 5474, [1980] CTC 1, 79 DTC 5479 (FCA)

In that connection the learned trial Judge quotes Prof H L Trevor-Roper thus: Each Bruderhof... is an agricultural family... but it is not only or mainly an economic organism. ...
FCTD

Pappas Estate v. The Queen, 81 DTC 5178, [1981] CTC 266 (FCTD)

A non-basement rear addition was subsequently added for storage purposes with an outside entrance from the lane at the rear and a connection with the front store from inside. ...
QCCA decision

A.G. Canada v. Thibault, 87 DTC 5085, [1987] 1 CTC 156 (Que. C.A.)

Il est vrai que le texte français de l’article 241 peut peut-être comporter une certaine ambiguité, absente dans la version anglaise qui se lit: 241(1)... (2) Notwithstanding any other Act or law, no official (...) shall be required, in connection with any legal proceedings, (a) to give evidence... ...
TCC

Miedzi Copper Corporation v. The Queen, 2015 TCC 26 (Informal Procedure)

There is no question there is a strong nexus between the listing services and the Stantec shares – they were the very shares listed, but the connection need not be one of a primary nor substantial nor directly related nature. ...
TCC

William G. Docherty v. Minister of National Revenue, 91 DTC 537, [1991] 1 CTC 2409 (TCC)

Without such connection, an equity to set off will not necessarily be granted, an intention to liquidate a debt by the other would have to be found (see section 130 Canadian Encyclopaedic Digest (Western), 3rd ed., Debtor and Creditor). ...
FCTD

Special Risks Holdings Inc. v. The Queen, 84 DTC 6054, [1984] CTC 71 (FCTD), aff'd 84 DTC 6215, [1984] CTC 563 (FCA)

Rules i of the court must be strictly followed, and the Crown is in no more favoured position than any other litigant in this connection, and no proceeding should be entertained, even if it might be found to have some relevance, when it seeks the introduction of material, which the parties could have sought to introduce many months earlier, and which if granted would have the effect of pre- venting the action from proceeding. ...
FCTD

Fearn v. The Queen, 95 DTC 5052, [1995] 1 CTC 127 (FCTD)

On his 1984, 1985 and 1986 tax returns, the plaintiff claimed business losses, in connection with Fane Island, of $37,783, $35,983.78 and $35,814.85 respectively. ...

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