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Fewer than 100 taxpayers, he said, had appealed to the Tax Court of Canada. [9]      The investigator also revealed that a certain number of donors who had claimed tax credits for substantial amounts pleaded guilty to charges brought against them under section 239 of the Act in connection with the scheme. ...

In that connection, she referred to the decision of this Court in Algoa Trust v. ...

In fact, the business losses claimed by the appellant for 1991, 1992 and 1993, that is, amounts of $9,558, $19,002 and $15,140 respectively, were disallowed in their entirety, but for 1994, the Minister reduced by $6,014 the business loss of $8,151 claimed leaving, as I understand it, the balance of $2,137 as an allowable loss. [2]            In so assessing the appellant, the Minister relied on the allegations of fact found in section 7 of the Amended Reply to the Notice of Appeal, which reads as follows: (a)            At all material times the Appellant was employed by the Carleton University as a professor of Musicology and Linguistics and his annual earnings from that source for the 1991, 1992, 1993 and 1994 taxation years were respectively $70,821.00, $77,205.00, $80,686.00 and $80,958.00; (b)            For approximately 20 years, the Appellant has been engaged in music critic and book writing activities (the "Activity") and reported losses and profit as shown on attached Schedule B;* (c)            At all material times, the Appellant's source of revenue from the Activity was from Le Droit and CBC Radio; (d)            The Appellant's travel expenses are in connection with trips made in various locations in North America and Europe; (e)            The said travel expenses referred to in subparagraph 7(d) herein have not substantially resulted in any income to the Appellant as reported on his income tax returns for the 1995 to 1998 taxation years; (f)             The Appellant is paid $80.00 per article from Le Droit; (g)            All the Appellant's income from the Activity is from Canadian sources; (h)            The Appellant's book Music and Science was published in 1995 as a limited university edition; (i)             The profit motivation is not the main reason for the Activity; (j)             The history of losses indicates a non-commercial intention; (k)            The Appellant does not have a set plan of action to increase gross income; (l)             The Appellant was given a reasonable number of years to demonstrate that the Activity was viable; (m)           At all relevant times, the Appellant had no reasonable expectation of making of profit from the Activity and; (n)            At all relevant times, the activity carried on by the Appellant was not a business and the expenses incurred by him were personal or living expenses.____________________ *               For reasons of convenience, Schedule B is reproduced at the end of these Reasons for Judgment. [3]            In paragraph 8 of the Amended Reply to the Notice of Appeal, the respondent further raised an alternative argument, which reads as follows: 8.             ...

Cook and Gregory in connection with their Examinations for Discovery. [4]            While counsel for the Appellants did not dispute the qualifications of Mr. ...

Where a loan is made for the purpose of earning income through the payment of dividends, this connection is sufficient to satisfy the purpose requirement of subparagraph 40(2)(g)(ii). [20]          In National Development Ltd. v. ...

Apart from the gathering of raw data, all other work was done in Canada and was substantially of the same nature as that carried out in connection with the Whale and Oldsquaw Projects. [33] I accept that the work done in Alaska could not have been carried out in Canada, and that it was an essential and integral part of the overall research project. [34] The Endicott Fish Project The purpose of this project was to determine the effects of the Endicott causeway on the coast of Alaska on the migration of the Arctic Cisco from the Mackenzie River (Canada) to the Colville River (Alaska). [35] The hypotheses tested were the following: 46. ...

The workers there also derived income from other sources including teaching students on a private basis without any connection to the Skating Club but this occurred only after the requirements of the contract between the coaches and the Club had been satisfied. ...

The sole connection with the Company was when they turned in their signed applications. ...

The said NATHAN REIBER does further acknowledge and agree that any income of proceeds received from or in connection with said vessel shall pass and enure to the benefit of said KEYSTONE YACHT SALES, INC. ...

But where there is credible evidence, as there is here, of actual use and enjoyment by the taxpayer of the contiguous land in connection with her house, and such use and enjoyment is not of an exaggerated or unnatural sort, a great deal of weight must be attached to it in assessing whether such use can be reasonably regarded as contributing to the taxpayer's use and enjoyment of his residence [In Rode v. ...