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So far as 1986 is concerned the question is whether a loss of $19,440.34 sustained in connection with a baseball team, the London Royals, is deductible by Mr. ...

“Residency” The essence of the position of the appellant was contained in the notice of appeal dated April 20, 1989: The appellant submits that he was not ordinarily resident in Canada at any time during the period 1982 through 1985 since he had become ordinarily resident in the United States in 1977 and had severed his permanent and durable connections with Canada in 1977. ...

Bodden in one connection, he was also involved with Mr. Bodden in his own (the appellant's) personal land assembly, and, as well, at the same time involved in marketing Cayman Islands properties in Vancouver. ...

Commenting on the application of paragraph 214(3)(a) of the Act, the author wrote as follows, at pages 21:20 and 21:21: An interesting argument arises as to whether paragraph 214(3)(a) effectively applies to subject a non-resident corporation in categories (1) to (8) above to Part XIII tax in connection with subsection 15(2). ...

Hradecky testified that he viewed the "devaluation" term of the first CN contract as one which, in the event that the production did not reach the stipulated rates, required the appellant to take back the equipment, refund the money with interest and compensate the buyer for loss of manpower and material in connection with the failed effort. ...

., [1965] C.T.C. 116, 65 D.T.C. 5069: In this case it is clear beyond all doubt that the expenditure was made “for the purpose of gaining or producing income” within the meaning of paragraph 12(1)(a) of the Income Tax Act, using as a criterion for such conclusion that it was made based on good commercial practice, and bearing in mind that it did not have to be incurred in gaining or producing the income of the particular period in which it was expended and that no causal connection had to be established between any particular receipt of income and this expenditure, and that it was an extraneous and non-recurring item of expenditure. ...

In connection with this operation, the company sold a large number of apartments. ...

He says that these taxpayers did not really know about accounts before they were opened in the name of a brokerage firm; had no connection with the brokerage firm. ...

They were directors in law only because of their family connection to Eugene Fitzgerald. ...

In this connection, the "revocation of clearance certificate” (D-16) signed on February 17, 1988 in no way benefits the plaintiffs at bar, who cannot rely on it. ...