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Archambault T.C.J. found that the expenses of that partnership incurred in connection with the unit rented to the taxpayer's wife (and a pro rata portion of interest on money borrowed to fund his partnership interest) were not incurred for an income-producing purpose. ...

The Queen, 2013 TCC 352 (Informal Procedure)-- summary under Section 135 Summary Under Tax Topics- Excise Tax Act- Section 135 The appellant ("CCAN") was a not-for-profit organization which, in connection with the promotion of environmental responsibility, would produce and distribute tailgate magnetic stickers, posters, signs, etc., to discourage idle engine operation. ...

In addition to doubting on the evidence that the partnership had made such a loan, Boyle J. noted that the loan had no apparent connection to the partnership's business. ...

The Queen, 2008 TCC 62-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) In finding that legal and other fees incurred by the taxpayer in connection with his prosecution for crimes committed while he was employed by a different corporation than the corporation which reimbursed him for those fees were, when so reimbursed, a taxable benefit to him, Tardif, J. noted that the test was whether the reimbursements were intended to remedy a prejudice caused by his employment and, on that basis, the reimbursements were a taxable benefit. ...

The Queen, 2003 DTC 2112, 2004 TCC 10-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 After finding that expenses incurred by the taxpayer in connection with a trip to Las Vegas by him and six other people including his wife and some Amway distributors were not deductible by virtue of not being incurred for an income-producing purpose, Lamarre J. went on to indicate that even if s. 18(1)(a) had not prohibited the deduction of the expenses, the expenses were so excessive as to be unreasonable and therefore non-deductible by virtue of s. 67, given that the expenses incurred for the trip represented one-third of gross income for the year. ...

MNR, 91 DTC 413, [1991] 2 CTC 2622 (TCC)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer, which regularly franchised restaurants, was found to have received on income account fixturing allowances which it received in connection with leasing space which it intended to sub-lease to franchisees. ...

The Queen, 99 DTC 47, [1998] 4 CTC 2584 (TCC)-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) Various expenses incurred in connection with the operation and supply of a pilot mill that was used in a bulk sampling operation qualified as CEE until the date that the mining company concluded (or should have concluded) that the deposit would not show the grade required to make a production decision. ...

The Queen, 2007 TCC 306-- summary under Agency Summary Under Tax Topics- General Concepts- Agency Woods, J. accepted that an agreement pursuant to which the appellant ("YSI") agreed to contract with suppliers in connection with refurbishing a yacht and to charge the other party to the contract ("Platinum") a 5% mark-up on some of the purchases, did not establish an agency relationship between YSI and Platinum. ...

MNR, 97 DTC 155, [1996] 2 CTC 2537 (TCC)-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) In connection with a buy-out of an individual's interest in a corporation ("Champagne") by his brother, the individual and his wife transferred their shares of Champagne to a newly-incorporated holding company, following which Champagne redeemed the transferred shares. ...

MNR, 90 DTC 1321, [1990] 1 CTC 2450 (TCC)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) write-down of land held as adventure The taxpayers, who acquired farm land in connection with an adventure in the nature of trade and not for use in a trade, were entitled to write down the carrying value of that land in accordance with the lower of cost and fair market value rule contained in s. 10(1). ...