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The Appellant has failed to establish any connection between these expenses and the Barcrest sale. ... M.N.R., 85 DTC 455. [27]             85 DTC 272 at 274. [28]             96 DTC 1686 at 1689. [29]             Paragraph 54(g)(iii)- Income Tax Act. [30]             Exhibit R-16- Appellant’s accountants calculations. [31]             Exhibit R-16- page 2. [32]             Exhibit R-16- page 2. [33]             Exhibit R-7- Letter dated April 27, 1989 from Helson Kogon to the Appellant enclosing statements setting out the amounts received and paid out in connection with the purchase and sale of Barcrest and the Nowak farm. [34]             The Appellant’s testimony with respect to Furlong’s involvement is inconsistent, if not contradictory. ...

If all or substantially all of the distance travelled by the automobiles in the total available days was not in connection with or in the course of the office or employment, then the assessment would stand. ... He kept no logs and other records and his memory was somewhat faulty, but I accept that he used the truck in connection with his work to the extent of 80% of the time. ...

That is, even where the security interest is created to secure an obligation, the administrative practice, in respect of mortgages at least, is that the "sale" of the property in the course of realizing on the security interest breaks the connection between the proceeds of sale and the entitlement of the mortgagor. Breaking the connection between the proceeds and sale and the entitlement of the tax debtor not only means that the requirements of paragraph 317(1)(b) are thereby not met but underlines that they are not a source of funds securing payment of the obligation. ...

The Appellant also argued that the Respondent had admitted both in the Reply and in the Agreed Statement of Facts that the excess amounts were payable. [9]            In connection with the contention that the interest payment was contingent, the Appellant relied on Justice Sharlow's comments in Wawang Forest Products Ltd. v. ... RESPONDENT'S SUBMISSIONS: [28]          Similarly, the Respondent acknowledged that the argument in connection with GAAR can be limited to a "misuse and abuse" analysis. ...

Kellogg Co. of Canada, [1943] S.C.R. 58, which allowed the taxpayer to deduct legal expenses incurred in defending a suit for an injunction against alleged infringement of registered trade marks by using certain words in connection with the sale of its products. ... But they were made with a view to protecting the income earning capacity of the company, since it must be assumed that the loss of the right to the use of the words in connection with its sales would have indirectly resulted in a reduction of its income, not only in the year in which they were incurred, but also in future years as well. [37]          Martland J., then held that the legal expenses which the taxpayer in the Premium Iron Ores Ltd. case had incurred in defending itself to protect income were deductible. [38]          Counsel made a reference to the cases of British Columbia Power Corporation Limited v. ...

I am satisfied that reasonable grounds existed for the appellant's belief that he had severed his connection with the Company as director and secretary-treasurer and concomitantly his responsibility for it when he placed his resignation in the hands of the Company's president and it was accepted by him. ... The Court was satisfied not only that he had reasonable grounds to believe that he severed his connection to the corporation, that is that he had reasonable grounds to believe that he was no longer a director, but that in fact, he gave up all his responsibilities, leaving them in the hands of the president of the corporation, Skuce, who eliminated any possibility of him having any role in the affairs of the corporation:   After 1 May 1984 the appellant played no role in the affairs of the Company because he believed that he had effectively terminated his responsibility in relation to it and, further, Skuce eliminated any possibility of this. ...

An important variation, for the purposes of this case, is in the degree of connection or relationship required between the transferor and transferee ...   [81]          I find that the Respondent in this case has not shown that there is a general policy in the Act to disallow losses on any transfer of property to persons with the same degree of connection as the Appellant and the Cross Family Trust. ...

It seems the only examples of direct supervision appear to be that management assigned a specific project to the Worker and briefed the Worker on what had to be done and the client expectations, approval of the overall plan and budget estimate created by the Worker, that the Worker had to get approval of any expenses over $2000 and the Worker’s statement that she reported to Drew Black on a daily basis, with no specific details in connection with same. ... Furthermore, ownership and supply of equipment must not be confused with ownership and supply of work instruments. [45]          In On Masse above, in a situation where the Worker was provided use of the appellant’s computer and software Webb J. stated in par. 13 that:   “ He needed to use the Appellant’s computer system and software to integrate his work with the work of the other individuals who were working on the film.” [46]          In my view the provision of those tools by the Appellant was just that; equipment necessary for the integration of work of the Worker with the Appellant, its staff and the Clients of the Appellant and was a necessity in order for the services to be performed, and practically speaking, in respect of the software and two way radio connection at least, only providable by the Appellant. ...

  [48]     However, the main problem with respect to these wire transfers is the lack of existence of a link or connection between the transfers through Sindi Financial or family/friends and the Vialink bank deposits. ... When he finally did provide the names of those individuals, with their telephone numbers, that had gifted/loaned him money, he did not go the step further and supply exact dates of receipts of these funds or the connection to the deposits to the Vialink account. ...

  [5]      The Appellant argued that it did not claim any ITCs for 1169 because these ITCs were in fact in connection with another construction which occurred concurrently with the construction of 1169 (Transcript, page 19). ...   [30]     As I understand the Respondent’s submissions, with respect to the income tax issues in connection to properties 3139 and 160, reliance is placed on section 69 of the Act to include in the Appellant’s income the proceeds of disposition of both these properties at FMV as established on resale by the Nowaks. ...