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Generally, a person who is experienced in business and financial matters is likely to be held to a higher standard than a person with no business acumen or experience whose presence on the board of directors reflects nothing more, for example, than a family connection. ...

The lack of precision, the lack of connection, the lack of records, the lack of documentation, the absence of an essential witness or 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. ...

At the hearing, four witnesses testified for the Appellant in connection with the Minister's allegation in paragraph 5(b) of the response to the notice of appeal. ...

These investigations, undertaken particularly in connection with the Société de l'Assurance Automobile du Québec confirmed that Mr. ...

Gauthier may have incurred some long distance charges in connection with the construction business during this time, there was insufficient evidence to prove what these expenses were. ...

Conclusion [8]      With respect to the Appellant's submissions regarding section 8 of the Act, the relevant provisions read: 8(1)       In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (f)         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 (i)          under the contract of employment was required to pay the taxpayer's own expenses, (ii)         was ordinarily required to carry on the duties of the employment away from the employer's place of business, (iii)        was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv)        was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer's income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that those amounts were not (v)         outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), (vi)        outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by the taxpayer, or (vii)       amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer's income for the year because of paragraph 6(1)(e); (i)          amounts paid by the taxpayer in the year as (i)          annual professional membership dues the payment of which was necessary to maintain a professional status recognized by statute, (ii)         office rent, or salary to an assistant or substitute, the payment of which by the officer or employee was required by the contract of employment, (iii)        the cost of supplies that were consumed directly in the performance of the duties of the office or employment and that the officer or employee was required by the contract of employment to supply and pay for, (iv)        annual dues to maintain membership in a trade union as defined (A)        by section 3 of the Canada Labour Code, or (B)        in any provincial statute providing for the investigation, conciliation or settlement of industrial disputes, or to maintain membership in an association of public servants the primary object of which is to promote the improvement of the members' conditions of employment or work, (v)         annual dues that were, pursuant to the provisions of a collective agreement, retained by the taxpayer's employer from the taxpayer's remuneration and paid to a trade union or association designated in subparagraph (iv) of which the taxpayer was not a member, (vi)        dues to a parity or advisory committee or similar body, the payment of which was required under the laws of a province in respect of the employment for the year, and (vii)       dues to a professions board, the payment of which was required under the laws of a province, to the extent that the taxpayer has not been reimbursed, and is not entitled to be reimbursed in respect thereof; [9]      I am unable to accept the submission that the Appellant is entitled to "gross-up" his income in both taxation years by the amount of the assistant's salary in order to allocate it between paragraphs 8(1)(f) and 8(1)(i). ...

The Appellant could still apply under the former subsection 176(1) because the contract was signed on June 15, 1996 i.e. before the July 1, 1996 deadline.   169.(1) Subject to this Part, where property or a service is supplied to or imported by a person and, during a reporting period of the person during which the person is a registrant, tax in respect of the supply or importation becomes payable by the person or is paid by the person without having become payable, the input tax credit of the person in respect of the property or service for the period is the amount determined by the formula   A × B   where   A         is the total of all tax in respect of the supply or importation that becomes payable by the person during the reporting period or that is paid by the person during the period without having become payable; and   B          is […]   (c) in any other case, the extent (expressed as a percentage) to which the person acquired or imported the property or service for consumption, use or supply in the course of commercial activities of the person.   123.(1) “commercial activity” of a person means   (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person,   (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and   (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply;   “ business ” includes a profession, calling, trade, manufacture or undertaking of any kind whatever, whether the activity or undertaking is engaged in for profit, and any activity engaged in on a regular or continuous basis that involves the supply of property by way of lease, licence or similar arrangement, but does not include an office or employment;   Case Law and Technical Notes   [5]      In Fedak v. ...

Moving expenses, as permitted by ss. 62(3), do not, as I see it, mean outlays or costs incurred in connection with the acquisition of the new residence. ...

., 1999 CarswellNat 562, [1999] 2 C.T.C. 2677, D.T.C. 3502 allowing the deductibility of amounts paid in 1994 and 1995 by a common law husband in connection with a relationship which had ended in 1988. ...

I shall deal with it in connection with the year 1994, but it has equal application to all the other years as well. ...