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It should be noted in connection with this purchase option that the sum of $37,500 had to be paid before the option could be exercised by defendant. ...

The Minister shall pay to the defendant all his reasonable and proper costs* [6] in connection with this appeal. 1 Actually they withdrew from the partnership to practise elsewhere. ...

He “habitually or systematically exercised” that business^:. [4] All the fees received in connection with the loans, be they interest, commitment fees, or stand-by fees, are income earned from the money lending business exercised by the plaintiff. ...

With regards to the nature and purpose of the payment, the Court found that it was dictated by business considerations, it was made to satisfy a legal obligation and it could be viewed as a reimbursement of excess compensation received: "[l]t was therefore a payment in connection with a business deal relating to the land trading activities of Shefner and of East End... on the whole of the evidence, Shefner made the payment of $443,000 in the course of his land trading activities and in consequence of his carrying on that type of business. ...

It is of some significance to note in this connection that the lands were entered in the books of the company in an account under the heading “Land for Resale*’. ...

BACKGROUND [3]                No tribunal record was requested in connection with this application for judicial review, and no tribunal record was filed. ...

See, in this connection, the decision of the Federal Court of Appeal in Hiwako Investments Limited v The Queen, [1978] CTC 378; 78 DTC 6281. ...

Additional encouragement will be provided to taxpayer’s in respect of drilling costs in excess of $5 million incurred in connection with an exploratory well. ...

Paragraph 248(1)(a) describes personal or living expenses as follows: 248. (1) In this Act, "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, Considering the evidence in its entirety, I find that the plaintiff's tree farm operation on the Orangeville property was a sideline business for which there was a reasonable expectation of profit realization in the future. ...

In addition, as part of the notices of assessment, the Minister refused to allow the deduction of automobile expenses including capital cost allowances claimed, and also disallowed the costs incurred by the plaintiff in connection with foreign exchange and alleged to constitute losses incurred as part of the investment activities of the plaintiff. ...