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By letter dated August 9, 1967 CIL and Chematur agreed concerning the distribution of this sum as follows: We wish to refer to the agreement between our companies, dated 27th June, 1960, concerning our purchase of rights under your continuous TNT process, and our recent correspondence in connection with our sale of rights under such process to the United States Government. ...

Two English decisions are worth noting in this connection. Firstly, there is the case of Mersey Docks and Harbour Board v Proctor, [1923] AC 253 at 258-9. ...

What it shows is that the Tax Court Judge became overly concerned about an issue that had no substantial connection with the outcome ...

In other words, without knowing what costs a family would bear for institutional care, there is no factual foundation for the conclusion that there is a causal connection between the quantum of tax relief for disability- related costs of home care and the choice between home care and institutional care. ...

Fogler, Rubinoff, $75,549.84 for their services in connection with these transactions. ...

In this connection, I refer to the remarks made by Major J., when rendering the unanimous judgment of the Supreme Court in Mitsui & Co. ...

(In this connection, the Tax Court Judge appears to have overlooked that a profit would have resulted in the absence of the depreciation charge which was an optional deduction.) [24]            The Supreme Court has now held that the reasonable expectation of profit test is not a relevant consideration in determining the existence (or continued existence) of a business where the activity in question is commercial-like and cannot be viewed as a personal pursuit (Stewart, supra at paragraph 47). ...

When the Directors of the Taxpayer passed the Value of Consideration for Share Issuance Resolution, it appears that they were complying with subsection 23(4) of the OBCA, which reads as follows: Value determined by directors Fixation de la valeur par les administrateurs 23. (4) The directors shall, in connection with the issue of any share not issued for money, determine, 23. (4) Lors de l’émission d’une action contre un apport autre qu’en numéraire, les administrateurs établissent: (a) the amount of money the corporation would have received if the share had been issued for money; and a) le montant que la société aurait reçu si l’action avait été émise contre un apport en numéraire; (b) either, b) et, selon le cas: (i) the fair value of the property or past service in consideration of which the share is issued, or (i) la juste valeur des biens ou du service rendu qui sert d’apport, (ii) that such property or past service has a fair value that is not less than the amount of money referred to in clause (a).  ...

" His reason for so concluding was that the liability created by subsection 227.1(1) was not absolute and if, through their personal conduct in connection with the company's failure to remit, the directors had exercised the degree of care, diligence and skill required to satisfy subsection 227.1(3), they were exempted from liability. [48]      Couture C.J.T.C.C. appears to have approached subsection 227.1(3) by asking whether the taxpayers had, in a broad sense, acted honestly and responsibly when faced with a difficult situation, and when the assignment to the bank of their accounts receivable had further restricted their ability to remit source deductions. ...

It is in that context that the Supreme Court held that other transactions entered into by the taxpayer in connection with the borrowing of funds were not relevant in determining the use to which the borrowed funds were put ...