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As pleaded, MDS says that these activities “constituted, in the relevant year, the manufacturing and processing of goods for sale and that its activities were performed in connection with the manufacturing or processing of goods for sale within the meaning of subsection 125.1(3) of the Income Tax Act, having regard to statutory, common law and other definitions and interpretations of the words ‘manufacturing and processing... of goods for sale.. ”’ As put by counsel for the plaintiff: Section 125.1 of the Income Tax Act permits a corporation to deduct from tax a certain percentage in respect of its ‘‘canadian manufacturing and processing profits’’. ... Regulation 5202 defines “qualified activities” as follows: ‘qualified activities’ means (a) any of the following activities, when they are performed in Canada in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease: (i) engineering design of products and production facilities, (ii) receiving and storing of raw materials, (iii) producing, assembling and handling of goods in process, (iv) inspecting and packaging of finished goods; (v) line supervision, (vi) production support activities including security, cleaning, heating and factory maintenance, (vii) quality and production control, (viii) repair of production facilities, and (ix) pollution control. (b) all other activities that are performed in Canada directly in connection with manufacturing or processing (not including the activities listed in subparagraphs 125.1 (3)(b)(i) to (ix) of the Act) in Canada of goods for sale or lease.” ...

(f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer's place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (vi) outlays or expenses that would, by virtue of paragraph 18(1)(I), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by him. ... Paragraph 8(1)(f) contemplates expenses which are in some substantial way connected to the earning of the employment commission income and such connection simply does not exist in the present case. ... There must be some closer connection than possible insolvency simpliciter, to qualify as an expense under paragraph 8(1)(f). ...

The reassessments arise from the plaintiff's claim for losses incurred in connection with a condominium he acquired in 1980. ... The statement of defence confirms that in reassessing the appellant, the Minister of National Revenue proceeded on the assumption that: (a) the expenditures claimed in respect of the condominium to the extent of $20,014.00 in 1981, $25,858.97 in 1982 and $42,663.21 in 1983 were not made or incurred for the purpose of gaining or producing income from business or property; (b) the expenditures were not made or incurred in connection with a rental property held for profit or with a reasonable expectation of profit; (c) the plaintiff's use of the condominium did not at any material time change from some other purpose to the purpose of gaining or producing income therefrom. ... Definitions. (1) In this Act, Personal or living expenses. — “personal or living expenses" includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

Bernazzoli's letter of April 8, 2002, by itself sets up sufficient content to constitute a new acknowledgment of debt once the prescription was acquired. [14]       As to the remittances of money made by Roméo Hébert to Annick Bertrand, the latter's affidavit, obtained as a result of actions taken by the judgment creditor, does not draw any direct connection between these remittances and the note. ... There is no explanation in the evidence as to why no such connection is drawn in this affidavit. Although the judgment creditor wishes to infer from the wording of this affidavit that such a connection is appropriate, the affidavit itself suggests instead that these remittances to Annick Bertrand occurred in the context of the operation of a drug trafficking business carried on jointly by Henri Bertrand and Roméo Hébert and in which Annick Bertrand acted as an employee of his brother. ...

The issue, between the parties and for decision, is whether the novelty soap products fall within the definition of cosmetics, as set out in subsection 2(1) of the statute: cosmetics means goods, whether possessing therapeutic or prophylactic properties or not, commonly or commercially known as toilet articles, preparations or cosmetics, that are intended for use or application for toilet purposes, or for use in connection with the care of the human body, including the hair, nails, eyes, teeth, or any other part or parts thereof, whether for cleansing, deodorizing, beautifying, preserving or restoring, and includes toilet soaps, shaving soaps and shaving creams, skin creams and lotions, shampoos, mouth washes, oral rinses, toothpastes, tooth powders, denture creams and adhesives, antiseptics, bleaches, depilatories, perfumes, scents and similar preparations; The issue is primarily one of fact. ... In my view, the words "are intended” apply not only to the phrase "for use or application for toilet purposes”, but also to the following words "for use in connection with the care of the human body...” ... The "similar preparations”, in my view, must relate to goods for use or application for toilet purposes, or use in connection with the care or grooming of the human body. ...

The provisions of the Income Tax Act in play are subsections (1), (2), (4) and (5) of section 231: 231. (1) Any person thereunto authorized by the Minister, for any purpose related to the administration or enforcement of this Act, may, at all reasonable times, enter into any premises or place where any business is carried on or any property is kept or anything is done in connection with any business or any books or records are or should be kept, and (a) audit or examine the books and records and any account, voucher, letter, telegram or other document which relates or may relate to the information that is or should be in the books or records or the amount of tax payable under this Act, (b) examine property described by an inventory or any property, process or matter an examination of which may, in his opinion, assist him in determining the accuracy of an inventory or in ascertaining the information that is or should be in the books or records or the amount of any tax payable under this Act, (c) require the owner or manager of the property or business and any other person on the premises or place to give him all reasonable assistance with his audit or examination and to answer all proper questions relating to the audit or examination either orally, or, if he so requires, in writing, on oath or by statutory declaration and, for that purpose, require the owner or manager to attend at the premises or place with him, and (d) if, during the course of an audit or examination, it appears to him that there has been a violation of this Act or a regulation, seize and take away any of the documents, books, records, papers or things that may be required as evidence as to the violation of any provision of this Act or a regulation. (2) The Minister shall, (a) within 120 days from the date of seizure of any documents, books, records, papers or things pursuant to paragraph (1)(d), or (b) if within that time an application is made under this subsection that is, after the expiration of that time, rejected, then forthwith upon the disposition of the application, return the documents, books, records, papers or things to the person from whom they were seized unless a judge of a superior court or county court, on application made by or on behalf of the Minister, supported by evidence on oath establishing that the Minister has reasonable and probable grounds to believe that there has been a violation of this Act or a regulation and that the seized documents, books, records, papers or things are or may be required as evidence in relation thereto, orders that they be retained by the Minister until they are produced in any court proceedings, which order the judge is hereby empowered to give on ex parte application. (4) Where the Minister has reasonable and probable grounds to believe that a violation of this Act or a regulation has been committed or is likely to be committed, he may, with the approval of a judge of a superior or county court, which approval the judge is hereby empowered to give on ex parte application, authorize in writing any officer of the Department of National Revenue, together with such members of the Royal Canadian Mounted Police or other peace officers as he calls on to assist him and such other persons as may be named therein, to enter and search, if necessary by force, any building, receptacle or place for documents, books, records, papers or things that may afford evidence as to the violation of any provision of this Act or a regulation and to seize and take away any such documents, books, records, papers or things and retain them until they are produced in any court proceedings. (5) An application to a judge under subsection (4) shall be supported by evidence on oath establishing the facts upon which the application is based. ... The Edmonton City Police Station is obviously not a place where any business is carried on or anything is done in connection with any business within the meaning of subsection 231(1). ... On the English version of the section I might be disposed to read these words as qualified by the words “in connection with any business”, but the French version of the section excludes that construction. ...

The Applicant did not receive notice of the extension as part of the appointment process, but was subsequently notified by the Acting Director in response to an inquiry from the Applicant’s union representative. [6] The Applicant initiated two requests for Individual Feedback [IF] in connection with the June 2022 staffing action, each of which was denied in decisions dated August 31, 2022 (amended September 6, 2022) and September 6, 2022. ... The Applicant also requested that “serious consideration” be given to an alleged deficient Certified Tribunal Record [CTR]. [8] The Respondent asserts that this matter is now moot as the Applicant has agreed to offer IF in connection with the extension of the temporary acting appointment, which will allow the Applicant to obtain an IF decision that can itself be reviewed. ... By providing the Applicant an opportunity to have IF in association with the June 2022 staffing extension, the CRA has agreed to effectively set aside the IF Decisions that denied the Applicant IF and to proceed with IF that covers the subject-matter of the Applicant’s IF requests. [14] While the Applicant raises the issue of procedural fairness in connection with scheduling the IF, I am not satisfied that any procedural unfairness has been established. ...

In the years 1982, 1983, 1984 he also deducted other expenses such as entertainment and promotion, car telephone, and capital cost allowance as well as supplies in respect of a computer which he purchased and used at home in connection with his work. ... (f) salesman's expenses.— where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer's place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year).... (h) travelling expenses.— where the taxpayer, in the year, (i) was ordinarily required to carry on the duties of his employment away from his employer's place of business or in different places, (ii) under the contract of employment was required to pay the travelling expenses incurred by him in the performance of the duties of his office or employment, and (iii) was not in receipt of an allowance for travelling expenses that was, by virtue of subparagraph 6(1)(b)(v), (vi), or (vii), not included in computing his income and did not claim any deduction for the year under paragraph (e), (f) or (g), amounts expended by him in the year for travelling in the course of his employment; 6(1) Amounts to be included as income from office or employment.— There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (b) personal or living expenses.— all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer.... ...

The legal expenses here in question were incurred in connection with that transaction. ... I say “mainly” and “practically all” to take into account a suggestion made by the plaintiff that all those legal fees disallowed by the Minister were not spent solely in connection with the Maple Leaf take-over; some would have been incurred in:protection of the credit position of the company with its bank. ... For the Minister, these legal expenditures were made in connection with the acquisition, the defending or the substitution of a capital asset; they were payments on account of capital or expenses incurred in connection with property the income from which would be exempt. ...

Wilkinson had before him the materials generated by CRA in connection with the first fairness request and he appears to have drawn upon that earlier report, in part, in writing his own report. ... Although the first of those assessments is not the subject of this application for judicial review, there are some obvious points of connection between the earlier review and the recommendation to deny relief made later by Mr. ... Lund's history of his dealings with CRA in connection with these assessments errors is correct, I do not believe that those actions could be reasonably described as regular collection action on a complex account. ...