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Defendant-petitioner raises an additional argument in connection with this however namely that these expenses were made in 1955 whereas the judgment of the Tax Review Board allowed expenses only during the period in question which ended with the 1954 taxation year. ...

Subsection 178(2) of the Income Tax Act [as amended by 1970-71-72, C 63] reads: 178. (2) Where, on an appeal by the Minister other than by way of crossappeal, from a decision of the Tax Review Board, the amount of tax that is in controversy does not exceed $2,500, the Federal Court, in delivering judgment disposing of the appeal, shall order the Minister to pay all reasonable and proper costs of the taxpayer in connection therewith. ...

One of the Gauvreaus had some business connections in Michigan, referred to in the evidence as the “Bay City group”, and arrangements were made with that group to obtain a loan of $25,000. ...

The Company shall employ such persons as may be necessary to Carry out its duties under this Agreement, provided that the Hotel shall provide all facilities and materials used or required in connection therewith and in particular water, cleaning and polishing supplies, and power, electrical or otherwise. 3. ...

In 1962 appellant, which regards itself as a manufacturing and processing corporation, and whose sales of goods processed and manufactured in Canada amounted to at least 50% of its gross annual income, took advantage of the provisions of section 40A of the Act which relate to production incentives, complied with the formalities required by the Act in this connection, and was in fact recognized by the Department as being entitled to the said deduction. ...

During this same year it realized a taxable capital gain of $5,906 from the disposition of real property which had been used or held in connection with the plaintiffs business. ... He might, to achieve a similar result, arrange with a retailer to give him a discount in return for undertaking to do all business with him, or he might for example purchase from a wholesaler if he had the proper connections to do so. ...

It is never necessary to show a causal connection between an expenditure and a receipt. ... In the three following years he claimed as deductions from other income his taxes, insurance and other expenses in connection with his property. ...

Bigelow, deducted losses incurred in connection with his raising of thoroughbred race horses in 1977, 1978 and 1979 in calculating his income tax for those years. ... See also paragraph 139(1)(ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

It reads as follows: 32-(3) Where a non-resident person carries on business with a resident person, and it appears to the Commissioner that owing to the close connection between the resident person and the non-resident person the course of business between those persons can be so arranged and is so arranged, that the business done by the resident person in pursuance of his connection with the non-resident person produces to the resident person either no profits or less than the ordinary profits which might be expected to arise from that business, the non-resident person shall be assessable and chargeable to tax in the name of the resident person as if the resident person were an agent of the non-resident person. ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5. ... The Queen, [1978] C.T.C 378; 78 D.T.C. 6281 (F.C.A.), the Chief Justice of the Federal Court stated at 384 (D.T.C. 6285) that the term “secondary intention”:... does no more than refer to a practical approach for determining certain questions that arise in connection with “trading cases” but there is no principle of law that is represented by this tag. ...