Search - connection

I don’t know whether this is coming through, the nature of a senior technical man who is somehow in demand and a firm such as this Canadian firm wishing to avail itself of a good name with good scholarly connections on an ad hoc basis. ...

The Moldowan (supra) quotations above were made in connection with a “farming business” appeal, and as it may be seen from James R Zavitz v MNR, [1978] CTC 3021; 78 DTC 1730, and from Her Majesty The Queen v James R Zavitz, [1981] CTC 17; 81 DTC 5007, there is a feature about the “business of farming” in which encouragement and flexibility is permitted to a taxpayer in getting established, or in surmounting economic fluctuation — by virtue of the “restricted farm loss provisions” of the Act, which is not permitted to that degree in other business ventures. ...

It is further understood that you undertake to supply to each prospective purchaser, prior to their entering into any form of agreement to purchase, the Prospectus as approved in connection with your application. ...

Mr Kelleher, indeed, according to the evidence had no particular connection with property business. ...

The value of a goodwill of a business is what a purchaser would be willing to give to keep the connection with which it consists, and I think that is precisely what was paid for in terms of the intangible value of both these businesses in 1973, 1974. ...

The respondent’s main argument is that in order for an expense to be deductible under paragraph 18(1)(a), there must be a link or direct connection with the taxpayer’s business. ...

However, unlike the taxpayers’ situation in Tonn, supra, there was a definite connection between the appellant’s hobby of woodworking, his expertise in the area of being able to construct and operate the 2-axis cutting machine, and the business activity he chose to pursue. ...

At page 256 the following is stated: When the material facts of the matter are examined, one finds that what transpired in 1955 and 1956 was simply this: Appellant’s numerous business connections, plus his own experience and capability, resulted in many and often large commissions being earned by him. ...

The material falls short of explaining a causal connection between the intended bankruptcy and events applicable to the 7 counts. ...

Appeal allowed. 1 1 Furlong report, section 2.7, p. 23 et seq. 2 ^Exhibit A-9 says “Coin du Pare-Brise”. 3 See Exhibits A-8 and A-9. 4 See Exhibits A-8 and A-9. 5 See Furlong report, pp. 31 and 32. 6 See in this connection two decisions referred to by counsel for the appellant: Immeubles Polaris (Canada) Liée c. ...