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Upon further consideration, EPA concluded that it would be practical only if the appellant moved to Toronto in connection with the commencement of his employment by EPA. ...

The $4,000 was paid to him by the university under a provision of the collective agreement that authorizes grants in connection with sabbatical leave that is intended to promote intensive scholarly and professional activity through sustained periods of concentrated research and study. ...

See also s. 139(l)(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. ...

"business" includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), section 54.2 and paragraph 110.6(14)(f), an adventure or concern in the nature of trade but does not include an office or employment; “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…. ...

The terms ’’taxable supply", "sale" and "commercial activity" are defined in subsection 123(1) as follows: ’’taxable supply" means a supply that is made in the course of a commercial activity; "supply" means, subject to sections 133 and 134, the provision of property or a service in any manner, including sale, transfer, barter, exchange, license, rental, lease, gift or disposition; "sale, in respect of property, includes any transfer of the ownership of the property and a transfer of the possession of the property under an agreement to transfer ownership of the property; “commercial activity" of a person means (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; Accordingly, G.S.T. is imposed on the provision of property in any manner, including sale, transfer, barter, etc. ...

In this connection, reference must be made to the following pieces of correspondence. ...

An asset purchase agreement dated December 22, 1987, made between Leonard Hryciw as "purchaser" who "offers and agrees to purchase upon the terms and conditions hereinafter set forth, the below described assets used in connection with the business known as J & L Video. ...

The appellant said that his name was identical to his father’s name and that his father had an outstanding guarantee of the corporation’s indebtedness and that he, the appellant, had been advised by his lawyers to sever his connection with the corporation due to difficulties in appellant’s financing of certain transactions arising out of disparaging remarks apparently made by bank officials on the basis of mistaken identity. ...

.), where six tests were listed: the nature of the property sold, the length of the period of ownership, the frequency or number of other similar transactions, work expended on or in connection with the property realized, the circumstances that were responsible for the sale and the taxpayer's motive. ...

—personal or living expenses of the taxpayer, other than travelling expenses incurred by the taxpayer while away from home in the course of carrying on his business; 248 (1) "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, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries; Analysis I have some empathy for Mr. ...