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There, a statutory tribunal had to construe the word “night” in a context which read: “... he is so severely disabled physically or mentally that he requires from another person, in connection with his bodily functions, frequent attention throughout the day and prolonged or repeated attention during the night...”. ...

It is said to have been signed by Zimmerman's Budapest connection. ...

In so reassessing the Appellant, the Respondent found or assumed: (a) the facts hereinbefore pleaded; (b) that the farm was maintained by the Appellant for his own use and benefit or for the use and benefit of persons connected with the Appellant by blood relationship or marriage and was not maintained in connection with a business carried on for profit or with a reasonable expectation of profit; (c) that the expenses incurred by the Appellant with respect to his farming activities were personal or living expenses of the Appellant and not outlays or expenses incurred during income from a business or property. 10. ...

None of these three appeared at the hearing or testified in connection with the matter. ...

The giving of evidence in court was considered to be an integral part of their duty and, therefore, the travelling expenses in connection therewith, while they were not on duty, were deductible. ...

The Appellant did not engage in any activity in connection with his investments in horses. ...

For the respondent — from the reply to notice of appeal: — The Appellant is employed as a sales engineer for United Electric; — in 1974, the Appellant purchased a farm from his father-in-law for $92,500.00, including a mortgage of $62,500.00; — from the time of the acquisition of the farm, no profit has been earned by the Appellant from its operation; — the farm was maintained by the Appellant for his own use or benefit, and for the benefit of persons connected with the Appellant by blood relationship or marriage and was not maintained in connection with a business carried on for profit or with a reasonable expectation of profit; — the expenses incurred by the Appellant with respect to the farm were personal or living expenses of the Appellant and not outlays or expenses incurred to earn income from the business or property. ...

The law is clear; there is no requirement that the outlay or expense should result in profit, either in the year of the expense or any other, nor is it necessary to show a particular causal connection between an expenditure and a receipt (see Royal Trust Company v MNR, 57 DTC 1055 (Ex Ct). ...

It should be noted in this connection that in the voluntary system of income declaration administered by the Department of National Revenue, only the taxpayer can decide for himself the extent to which his record keeping for business or personal purposes will also be adequate, if needed, in the determination of income tax liability for departmental purposes. ...

—personal or living expenses of the taxpayer except travelling expenses (including the entire amount expended for meals and lodging) incurred by the taxpayer while away from home in the course of carrying on his business; “Personal or living expenses" — “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. 4.02 Cases at Law The cases at law referred to the Court by the parties are: 1. ...