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The appellant testified that he has held a United States "Green Card" since 1978 which was granted in connection with his investment in and activities connected with Road Planing, Inc. ...

These two cases dealt with the same subsection 180.2(1) but in connection with Old Age Security benefits under the Old Age Security Act, R.S.C. 1985, c. ...

.), Rouleau, J. finds it is necessary to examine all the circumstances including the nature of the property sold, the length of the period of ownership, the frequency or number of similar transactions, the work expended on or in connection with the property realized, the circumstances that were responsible for the sale of the property and the motive (i.e.) the intention at the time of acquisition as inferred from the circumstances at that time. ...

The purpose of subsection 96(1.1) is clearly not to determine how to calculate the income or loss of a retiring partner in connection with his assessment for a taxation year, taking into account the allowance resulting from the agreement in question, but simply to create a fiction which only applies for the purposes of subsection (1) and sections 101 and 103 of the Act. ...

.”, since that part of section 42 is strictly a particular definition which simply excludes such a "restaurateur, caterer or other person engaged in...” from the specific expressions "producer or manufacturer” when those expressions are used in connection with Part VI of the Act. ...

Lastly, in the same connection, I refer to the decision of the Ontario Court of Appeal in OPSEU v. ...

Ball, can you describe for us your activities in connection with donations, the timing of them, the dollar volumes involved and perhaps lend some perspective of the other thing you were doing in your life at the time in your business? ...

It should be remembered in this connection that the appellant was absent from his work and out of the country for a number of weeks in the fall of 1987. ...

Section 23 reads as follows: 23.(1) Subject to the articles, the by-laws, any unanimous shareholder agreement and section 26, shares may be issued at such time and to such persons and for such consideration as the directors may determine. (2) Shares issued by a corporation are non-assessable and the holders are not liable to the corporation or to its creditors in respect thereof. (3) A share shall not be issued until the consideration for the share is fully paid in money or in property or past service that is not less in value than the fair equivalent of the money that the corporation would have received if the share had been issued for money. (4) The directors shall, in connection with the issue of any share not issued for money, determine, (a) the amount of money the corporation would have received if the share had been issued for money; and (b) either; (i) the fair value of the property or past service in consideration of which the share is issued, or (ii) that such property or past service has a fair value that is not less than the amount of money referred to in clause (a). (5) In determining the value of property or past service, the directors may take into account reasonable charges and expenses of organization and reorganization and payments for property and past service reasonably expected to benefit the corporation. (6) For the purposes of subsection (3) and of subsection 24(3), a document evidencing indebtedness of a person to whom shares are to be issued, or of any other person not dealing at arm’s length with such person within the meaning of that term in the Income Tax Act (Canada), does not constitute property. ...

Paragraph 8(1)(h) of the Act reads as follows: 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: (h) where the taxpayer, in the year, (i) was ordinarily required to carry on the duties of his employment away from his employer's place of business or in different places, (ii) under the contract of employment was required to pay the travelling expenses incurred by him in the performance of the duties of his office or employment, and (iii) was not in receipt of an allowance for travelling expenses that was, by virtue of subparagraph 6(1)(b)(v), (vi) or (vii), not included in computing his income and did not claim any deduction for the year under paragraph (e), (f) or (g), amounts expended by him in the year for travelling in the course of his employment; Subparagraph 6(1)(b)(v) of the Act reads as follows: (1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (b) all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer, The facts on which the respondent relied in assessing the appellant are described in paragraph 6 of the reply to the notice of appeal and are as follows: In making and confirming his assessment the respondent, the Minister of National Revenue, relied, inter alia, on the following presumptions of fact: (a) during the 1982 taxation year the appellant was employed by Bell Canada as a representative; (b) during the year at issue the appellant was also president of the Bell Canada telecommunications advisors union, a position for which he received no pay from the union; (c) during the taxation year at issue, the appellant was required to perform the duties of his employment away from his employer Bell Canada's place of business; (d) during the taxation year at issue, the appellant was reimbursed by his employer Bell Canada for all the expenses incurred in performing his duties; (e) with respect to travelling expenses, the appellant used his automobile for business purposes, covering 7,538 km in 1982; (f) Bell Canada paid the appellant the sum of $1,971.29 to compensate him for fixed and variable costs incurred in covering the 7,538 km mentioned above; (g) this amount is very reasonable and consisted of a fixed allowance of $41 per month and a variable allowance of 20.5 cents/km, and the respondent did not tax these amounts; (h) as to the expense for office rental, the appellant was not employed by the Bell Canada telecommunications advisors union and received no pay from them; [Translation.] ...