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Simon's Income Tax 1964-65, Vol. 1, has this to say at page 59 in connection with the case of C./.R. v. ...

There need not be any connection between farming and the 'other source of income’ for a taxpayer's chief source of income to be a combination of the two sources, however, the meaning of ‘combination’ in section 31 does not mean the simple addition of any two sources of income for any taxpayer (Moldowan, op cit, page 314; D.T.C.5216). ...

Sykes in connection with the meetings. Certainly Mr. Sykes did not do all the entertaining. ...

In the Spofforth and Prince case (supra), a firm of chartered accountants claimed in the computation of its profits the deduction of certain legal expenses paid in connection with the successful defence of one of the partners who had been charged with conspiracy to defraud the Revenue. ...

That stands in considerable contrast with, as we have here, an obligation to remove all merchantable timber at an aggregate gross specified price within a short specified time in connection with and for the purpose of enhancing the efficiency of farm land use. ...

There need not be any connection between farming and the 'other source of income” for a taxpayer's chief source of income to be a combination of the two sources; however, the meaning of “combination” in section 31 does not mean the simple addition of any two sources of income for any taxpayer (Moldowan, op cit, page 5216). ...

It may be noted at once, in connection with this overvaluation, that the defendant cannot rely on that here as it never made use of the provisions of section 46 of the Customs Act to request a new ruling or valuation; furthermore, what it allegedly overpaid is not the subject of a separate claim or of a counterclaim. ...

In order that the proceeds arising out of a liability under any such contract should become taxable under section 6(1)(a) of the Act, a connection thereto must be found, as I see it, with the contract of employment. ...

:—These are appeals heard on common evidence in Toronto, Ontario, on June 5, 6 and 16, 1986, in connection with a 1977 income tax assessment for Humphreys Jones Realty Limited ("Humphreys Jones’’) and 1978, 1979 and 1980 assessments for Browview Realty Limited ("Browview") resulting from the allocation by the Minister of National Revenue of the selling price of a parcel of real property in the City of Hamilton as follows: Land $ 604,800.00 Buildings 1,205,300.00 Equipment 22,400.00 $1,832,500.00 Humphreys Jones had reported the allocation of the selling price as: Land $ 784,000.00 Buildings 1,026,100.00 Equipment 22,400.00 $1,832,400.00 In its own relevant income tax returns Browview had treated the purchase price as: Land $ 271,515.00 Buildings 1,538,585.00 Equipment 22,400.00 $1,832,500.00 The basic facts as noted in the Humphreys Jones reply to notice of appeal were: On or about September 16, 1977, the Appellant agreed to sell to Ben Feldman in Trust for a company to be incorporated six apartment buildings comprising 224 suites (the ‘Buildings’) in the City of Hamilton as well as the land on which the Buildings were situated (the "Land’) for a price of $1,832,500.00. ...

I suggest that this is what is meant by “in connection with the manufacturing and processing... of goods...” referred to in Regulation 5202 — “qualified activity”. ...