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(e) “listed personal property” of a taxpayer means his personal-use property that is all or any portion of, or any interest in or right to, any (i) print, etching, drawing, painting, sculpture, or other similar work of art, (ii) jewellery, (iii) rare folio, rare manuscript, or rare book, (iv) stamp, or (v) coin; (f) “personal-use property” of a taxpayer includes (i) property owned by him that is used primarily for the personal use or enjoyment of the taxpayer or the personal use or enjoyment of one or more individuals each of whom is (A) the taxpayer, (B) a person related to the taxpayer, or (C) where the taxpayer is a trust, a beneficiary under the trust or any person related to the beneficiary, 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. 251. (2) For the purpose of this Act “related persons”, or persons related to each other, are (a) individuals connected by blood relationship, marriage or adoption. 4.02 Analysis 4.02.1 In November 1975, the appellant’s husband left Barrie, Ontario, and moved to Winnipeg, Manitoba. ...

In this connection I would quote one paragraph from the argument of Mr Farano, QC counsel for the appellant in this matter where he is referring to Brazolot (supra): In that case it was held that a legal obligation to pay was created even without anything in writing. ...

As a final point Mr Overdyk raised the matter of the “Charter of Human Rights”, not simply the issue of the reverse onus of proof resting on the shoulders of taxpayers in an income tax appeal, but rather in connection with perceived discrimination as he read certain sections of that Charter which he believed applied to his condition. ...

Given that it has already been established in this case that the appellant was not a partner in the law firm, it must necessarily be concluded that the only other connection that there could be between him and the firm was that existing between an employee and his employer, at least in so far as the application of the Income Tax Act is concerned. ...

(Every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to him as, on account or in lieu of payment of, or in satisfaction of, payment for a right in or to the use of (a) a motion picture film, or (b) a film or video tape for use in connection with television that has been or is to be used or reproduced in Canada (the italics are mine). ...

By “benefit received thereunder” he meant that “the benefits were all of the meetings taking place on that boat in connection with the business of BACM”. 3.04 In re-examination, the appellant testified that: (a) Concerning personal use, from 1967 to 1977, “I don’t think I used it three times”; (b) in 1962, 1963 and 1964 when the 2 children were at home, the boat was used more often for the family. 3.05 Mr Leo Alfred testified that: (a) in 1975, he was working for BACM as shop foreman in the mechanical and he has been with this company since 1963; (b) in 1975, he had to remove the two motors of the inboard and give them an overhaul. ...

In connection with the share issue, United Trust entered into an agreement with Pitfield, pursuant to which Pitfield served as a distribution vehicle by taking title from United Trust in two certificates and issuing new certificates to the individual purchasers but which involved a number of other services to United Trust including advice in establishing the $8 price, public identification as underwriter at that price and a successful sales promotion, as a result of which the issue was fully taken up by the public. ...

From time to time they contained notices of dividends, annual meetings and the loss of certificates in connection with companies whose securities were listed on the Exchange. ...

Five months later, however, on March 22, 1974, the appellant sold the building because the principal tenant, Holiday Magic, had been visited on two occasions by city police in connection with its pyramid sales opera tions. ...

Under the agreement the appellant was to:... act as the business editor of Global News and... perform such other journalistic functions in connection therewith as may reasonably be required from time to time. ...