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In view of the provisions of subsection 178(2), the Minister shall bear the reasonable costs of the taxpayer in connection with the appeal. ...

The plaintiff owns a railway line running north of Lake Erie between the Detroit River and the Niagara River alaong with a number of branch lines in Canada and appurtenant facilities including most notably, connections with US lines at or near Detroit, Niagara Falls and Buffalo, a railway tunnel under the Detroit River and a bridge across the Niagara River, hereafter, collectively “the system”. ...

The amount here in controversy does not exceed $2,500.00, and in accordance with subsection 178(2) of the Act I order the Minister to pay to the defendant all reasonable and proper costs of the defendant taxpayer in connection with this appeal. ...

They were losses incurred in connection with a capital venture... I think it is clear that an expenditure incurred for the purpose of enabling a taxpayer to decide whether a capital asset should be acquired [1] is an outlay or payment on account of capital..., Counsel for the plaintiff relied on the judgments of Noël, J in Bowater Power Co Ltd v MNR, [1971] CTC 818; 71 DTC 5471; and Pigott Investments Ltd v The Queen, [1973] CTC 693; 73 DTC 5507. ...

The Minister shall pay to the defendant all his reasonable and proper costs* [3] in connection with this appeal. 1 Regal Heights Ltd v MNR, [1960] S.C.R. 902, per Judson, J at 907; [1960] CTC 384 at 390; 60 DTC 1270 at 1273; MNR v Foreign Power Securities.Corp Ltd, [1967] S.C.R. 295, per Cartwright, J at 297; [1967] CTC 116 at 117; 67 DTC 5084; Irrigation Industries Limited v MNR, [1962] S.C.R. 346, per Cartwright, J, dissenting, at 360; [1962] CTC 215 at 229; 62 DTC 1131 at 1138. 2 “See for a somewhat similar factual situation with a different result, Thrasher v The Queen, [1975] CTC 66; 75 DTC 5029. ...

Schubert said that the banks readily loaned as high as $70,000 in connection with the business. ...

The length or complexity of a case or the volume of work required in connection therewith are not sufficient factors by themselves to warrant a special direction as to costs under Rule 344(7). ...

The Tax Review Board came to the conclusion that the deduction was allowable, in view of the facts that Doral was only the corporate vehicle Mr Schuchmann had always intended to use for his participation in the East End project; that the loan had been made at a time when the affairs of East End were good and Doral had reason to believe that a large incomeproducing future lay ahead as a result of its connection with it; that Doral had made the loan in an arms-length transaction with the intention of providing financing on the understanding that it would continue to earn income. ...

Counsel at the close of argument requested that if I came to a conclusion along these lines I should leave it for counsel to settle the terms of the judgment by agreement, there being some potential problems in connection with timing. ...

C.A.)] 11 So too, where investment income is at issue, it must be viewed in relation to its connection to the Reserve, its benefit to the traditional Native way of life, the potential danger to the erosion of Native property and the extent to which it may be considered as being derived from economic mainstream activity. ...