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An application for subdividing the land was made to the City of Calgary and, if my understanding is correct, some preliminary grading for an access road was done by the developers in connection with the proposed warehouse (Exs A-27 to A-35). ...

In this connection, I quote the words of Jackett, CJ, then President of the Exchequer Court, in the case of Canada Steamship Lines Limited v MNR, [1966] CTC 255; 66 DTC 5205, in which, at page 259 [5208], he states:... ...

The subparagraphs which might allow the appellant to deduct some expenses are 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: (f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer’s place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by him; (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 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; (i) amounts paid by the taxpayer in the year as (ii) office rent, or salary to an assistant or substitute, the payment of which by the officer or employee was required by the contract of employment, (iii) the cost of supplies that were consumed directly in the performance of the duties of his office or employment and that the officer or employee was required by the contract of employment to supply and pay Tor, to the extent that he had not been reimbursed, and is not entitled to be reimbursed thereof; As stated, from a “radio business” point of view the appellant was not entitled to deduct any expenses from his income in that respect as he was not in the “radio business” in 1972 and 1973. ...

., “qualified activities” means (a) any of the following activities, when they are performed in Canada in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease: (i) engineering design of products and production facilities, (ii) receiving and storing of raw materials, (iii) producing, assembling and handling of goods in process, (iv) inspecting and packaging of finished goods, (v) line supervision, (vi) production support activities including security, cleaning, heating and factory maintenance, (vii) quality and production control, (viii) repair of production facilities, and (ix) pollution control, Counsel for the appellants, through two witnesses, Mr Latimer, a chartered accountant, and Mr Hamilton Piercy, a professional engineer, introduced evidence both verbal and documentary in support of the following positions: (a) that the activities of the appellants in “processing” were “qualified activities” under Regulation 5202; (b) that the appellants gathered and processed the broadcast signal, not a television program; (c) that such broadcast signal was electricity, and that electricity had been held previously to be a “good”; and (d) that the broadcast signal was public property at the time it was interrupted and, thus having been captured, became the property of the appellants to sell. ...

Did Matthews have a connection with Rousseau? Was that the quid pro quo for putting Rousseau into the deal? ...

Although there are, no doubt, other applicable criteria, it would seem to me that bonuses that do not meet these criteria would simply be a profit-sharing arrangement having no connection with the earning of income and would therefore not be considered as deductible outlays or expenses. ...

Based on comparable sales of properties and verified through the land titles office, the report indicates that land used for redevelopment is just over $2 a square foot but that the land in connection with properties purchased as rental houses has a value of $1 to $1.50 a square foot. ...

The deduction was claimed in connection with a reserve for a quadrennial survey originally set up in 1967 by Mr Huxtable as the beneficial shareholder of Bedford Investments Limited when it was known as Newfoundland Canada Steamships Limited. ...

However, Gibson did act as agent for the partnership in connection with the claiming or disposition of a horse. ...

The parties agree: (i) THAT if the Court is of the opinion that the question is to be answered in the negative the appeal is to be allowed and the assessment referred back to the Minister of National Revenue for re-assessment on the basis that the Plaintiff was not resident in Canada, was not employed in Canada and was not carrying on business in Canada subsequent to June 10, 1971; (ii) THAT if the Court is of the opinion that the question is to be answered in the affirmative the appeal is to be dismissed; (iii) THAT under the provisions of sub-section 178(2) of the amended Income Tax Act and without regard to the outcome of the appeal the Plaintiff shall be awarded all his reasonable and proper costs in connection therewith. ...