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On February 16, 1976, Norbraten entered into an agreement with Redco to provide architectural services in connection with renovation to the Donahue Block. 3. ...

He had the “artistic control” of the commercial. 3.13 He further explained his function under this arrangement with Cinera as follows: Prior to the pre-production stage, I guess it must be mentioned again that part of my time and energy would be spent in dealing with clients and convincing them that they should work with me in connection with a company called Cinera, Cinera being the producer, myself being the director. ...

The company claimed 90% of the expenses. 3.04 Concerning the accounting fees, the appellant testified they were paid in connection with the preparation of financial statements and the basic accountancy services performed for the company (SN p 31). 4. ...

The latter definition reads as follows: “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, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries. 4.02 Cases at Law 1. ...

It was also his recollection that the delay in connection with the transfer of document A233952 from February 6, 1979 when it was prepared, until July 24, 1979 when it was registered, resulted from a local committee of adjustment technicality which he had not been able to clear up before that date. ...

That would raise the question of not only the requirement for the claimed expenses in order to gain the relevant income, but also the reasonableness of those expenses in connection with that income. ...

It is also to be noted that these assessments were ill-founded on the merits, and the Minister has agreed that a substantial portion of the Notices of Objection filed in connection therewith were well-founded. ...

In this connection, reference should be made to the case of J Mercer Reid v MNR, 26 Tax ABC 321; 61 DTC 263, where, on dismissing the appeal, the Board noted at 326 and 266 respectively: As to paragraph (b) it includes in the income of a shareholder funds or property of a corporation which have been appropriated in any manner whatsoever to or for his benefit otherwise than on the reduction of capital, redemption of shares, or on the winding-up, discontinuance or re-organization of the company’s business. ...

These amounts represent holdbacks equivalent to 10% of the payments made by Hydro-Québec to the appellant during the years in question pursuant to a contract for the manufacture, delivery and, in part, pouring of concrete in connection with the development of the Outardes II hydro-electric station. ...

On or about March 3, 1977 Mr Fiore received a request from the Department to forward certain documents in connection with the Property, including: (a) purchase agreement; (b) trust agreement; (c) sale agreement. 24. ...