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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. ...

Even assuming, without admitting, that there is some connection between the Appellant and the said shareholder advance account...the relevant accounting entries are dated as being made in 1991 and do not support the contention that the Appellant acquired interests in the joint ventures in 1989 or 1990; (g) the investment had already been made, according to Mr. ...

There is no direct connection between their income and the loans. Nor did the appellants own the shares of any of the borrowers as an adventure in the nature of trade rather than a capital investment. ...

Feldgajer in connection with what the respondent somewhat grudgingly describes as the “consulting activity” (no doubt to avoid any suggestion of an admission that what he was doing was carrying on a business). ...

Each of the actions listed above represent relief to the taxpayer of the assessment in connection with which the appeal was taken. ...

It would be unreasonable to conclude that the appellant ceased overnight to have a reasonable expectation of profit in connection with the rental property as soon as the slump in the real estate market occurred. ...

The “reasonable expectation of profit” test originates from the extended definition of “personal or living expenses” found in section 248 of the Income Tax 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.... ...

While the added paragraph (f), unlike the preceding paragraphs, further expands the definition by reference to functions carried out in connection with goods, it does not, in my opinion, give rise to an inference that such functions necessarily constitute “manufacture or production” or “manufacturing or producing" within the meaning of any of the provisions of the Act. ...

Bad debts The same rather confused state of affairs prevails in connection with the claim to deduct bad debts of $21,605. ...

McGrath further emphasized that the federal government collection business that came through this connection was periodically up for tender, and that business could easily be lost in the contract-tender process. ...