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In this connection, the appellant mentioned that at the time the Company sold its preference shares to Llandaff there was an understanding between the appellant and the President of Llandaff, Mr. ...

Considering the above in connection with the facts of the instant case we have: 1. the claim for $212,409 consisted of $3,000 for the purchase of capital stock in Sumas; and $209,409 for construction, development, operation etc. of the Sumas plant. ...

Analysis First, I would note that in connection with Exhibit A-3 above, Mr. ...

His only significant connection with Canada was his wife’s continuing residence in Hamilton and special reasons existed to justify her remaining in Canada. ...

., subject to sub-paragraph b) hereof, the sum of $227,000.00, in consideration of which S.R.C. renounces any other recourse in this connection; and K.B.R. renounces any other recourse against S.R.C., except as herein provided, by reason of the partial execution of the work and the cancellation of the sub-contract, assuming for its own account, except as herein specified, the job site as it now is and as if K.B.R. had executed the work from the beginning. b) Of the said sum of $227,000, $200,000 shall be payable within ten days hereof, and the remaining $27,000 on 31 July 1978 unless K.B.R. can prove substantial lack of the co-operation or lack of the consents referred to in paragraph 5c) hereof. ...

Referring to a letter from his accountant dated May 8, 1981, and addressed to the respondent, counsel for the respondent questioned the appellant's credibility in this connection. ...

Paragraphs 8(1)(a), 8(3)(a.1) and 18(1)(p)(iii) provide: 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: (a) a single amount in respect of all offices and employments of the taxpayer, equal to the lesser of $500 and 3% of the aggregate of (i) his incomes for the year from all offices and employments (other than the office of a corporation director) before making any deduction under this section, and (ii) all amounts included in computing his income for the year by virtue of paragraphs 56(1)(m) and (o). 8(3) In computing a taxpayer's income for a taxation year, no amount is deductible under paragraph (1)(a) (a.1) if the taxpayer was in the year an incorporated employee and a specified shareholder (within the meaning assigned by paragraph 125(9)(c)) of a corporation that has deducted an amount described in subparagraph 18(1)(p)(iii) in computing its income for its taxation year ending in the year. 18(1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (p) an outlay or expense to the extent that it was made or incurred by a corporation in a taxation year for the purpose of gaining or producing income from a personal services business (within the meaning assigned by paragraph 125(6)(g.1)), other than (iii) any amount expended by the corporation in connection with the selling of property or the negotiating of contracts by the corporation if the amount would have been deductible in computing the income of an incor- porated employee for a taxation year from an office or employment if the amount had been expended by the incorporated employee under a contract of employment that required him to pay the amount that would, if the income of the corporation were from a business other than a personal services business, be deductible in computing its income. ...

They live in Zimbabwe and it appears that their only particular relationship to Canada arises out of their connection with the appellant. ...

McAllister was maintained in connection with a business carried on with a reasonable expectation of profit. ...

It is legal fees incurred in connection with these proceedings, relating to the injunction and contempt of court, which appellant claims to be able to deduct in computing its income. ...