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The Queen, 90 DTC 6322 (FCA) was distinguished on the grounds that here there was no connection between the loans and the original cost of the residence and that in that decision, "the Federal Court of Appeal did not have put to it nor did it consider the implications of barter" (p. 1147). ...

The Minister disallowed all the taxpayer's business deductions in connection with the franchise, on the basis that there was no business activity, and that the franchise and note were shams entered into predominantly for tax reasons. ...

However, it was found that they were not "tangible property attached to a building" for purposes of paragraph (b) of Class 8 because "the words 'attached' in the English language version of clause (b)(ii) means more than a mere connection; the tangible property must be so attached to the building that it more or less becomes part of it" (p. 1862). ...

However, it was found that they were not "tangible property attached to a building" for purposes of paragraph (b) of Class 8 because "the words 'attached' in the English language version of clause (b)(ii) means more than a mere connection; the tangible property must be so attached to the building that it more or less becomes part of it" (p. 1862). ...

The Queen, 2008 TCC 62-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) mere error is insufficient The failure of the taxpayer to include in his income the reimbursement by a corporation of expenses incurred by him in connection with a criminal prosecution of him did not permit the Minister to assess the year in question beyond the statute-barring period, given that the correct treatment of such reimbursements was by no means clear. ...

Regarding the taxpayer's submission that it had reasonable grounds to believe that no taxes were owed in connection with the late-filed returns, Hogan J. stated: To succeed with this defence, the taxpayer must show how the error was made and demonstrate that he relied on the error in deciding to postpone the filing of the returns beyond their due date. ...

That her employer was Native Leasing Services or that most of her students were status Indians were not enough to establish such a connection. ...

The Queen, 2013 DTC 1203 [at at 1083], 2013 TCC 247 (Informal Procedure)-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit LP for daughter's tennis training expenses When his daughter was nine years old, the taxpayer created the "Tennis Mania LP," which used the funds contributed by him to reimburse him for expenses incurred by him in connection with her training and development as a tennis player. ...

The Queen, 2007 TCC 306-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) 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. ...

In connection with noting that the children had not disclaimed their interests in the RRSPs, V. ...