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Work expended on or in connection with the property realized. [...] 5. ...

In those same years, the Appellant had loans receivable of $1,063,588 and $945,028 in connection with the development of its mobile home parks in prior years. ...

On or about August 31, 1994, Revenue Canada began to audit APCR’s tax return for its 1993 taxation year with regard, inter alia, to the investment tax credits claimed by APCR for scientific research and technical development expenditures incurred in connection with the research agreement. ...

Next are two payments, apparently made to Ace Travel Agency, and the total amount in connection with those is $4,266.57. ...

I believe that the evidence is not sufficient to establish a connection between the fact that Mr. ...

T.C. 1984), at 328, the taxpayer alleged that their tax returns had been selected for examination because of their supposed family and business connections with persons purportedly involved in organized crime. ...

In particular, at pages 6423 to 6424, Justice Rouleau has reviewed those several tests, and they include: The nature of the property sold, the length of ownership of the property, the frequency or number of other similar transactions by the taxpayer, 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. ...

Prior to the acquisition of a portion of these lots, the appellant and the City of Mascouche had signed a memorandum of understanding pursuant to which the parties made various commitments in connection with the development planned by the City of Mascouche (the Memorandum of Understanding). [3] The Minister was of the opinion that this $11,835,218 gain did not constitute a capital gain, as reported by the appellant, but was in fact business income taxable as such under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ...

Geddes testified she never spoke with her. [22] Nothing on the record establishes what the appellant knew, or believed, or what she did or did not do in connection with the preparation or filing of her 2008 return. [23] The respondent submitted that because the assessment was a net worth assessment, once the appellant conceded she had unreported income and did not provide a reasonable explanation for it, the Minister has discharged her burden. ...

., extensive income, allegedly unreported, in connection with the activities of OA and Paxum Inc., resulting from the sale of natural supplements. ...