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(iii)             From the completion date to June 19, 1991, the Corporation had undertaken efforts to recover money (withholdings, extras and damages) that it was owed by The Guarantee and SIMQ in connection with the performance of the contract that was awarded to it on July 2, 1985.   ...   [24]     First of all, I am of the opinion that the amount of $720,000 which was received by the Corporation in connection with the out-of-court settlement of the action to collect a debt from The Guarantee and SIMQ was clearly compensation awarded by reason of a failure to pay an amount that would have constituted income if it had been received. ...

[My emphasis] [20]     Of the decisions to which Counsel for the Respondent referred, I would cite the following paragraph of the Anderson decision (supra), handed down by Justice Rip, where he mentions that this is not a case in which the damages received are unrelated to the loss of employment, for example, when the taxpayer was the victim of defamation, as in Bédard, nor a case in which the damages received were for mental and physical injuries suffered during employment, as in Stolte. [21]     Paragraph 13 of the Anderson (supra) decision reads as follows: 13         On the facts before me, there is a sufficient connection between the receipt of the money by Mr. ... The courts in this connection have displayed considerable flexibility and also at times have granted damages for psychological harm and defamation arising out of the actions of the employer and the loss of other income subsequent to the breaking of the contract. [24]     The Appellant maintains that he received part of the $105,000, namely approximately $69,000, for psychological damages. ...

No documentary evidence was supplied in connection with this.   The accountant says that his clients received $100 per person per week, i.e. $300 per week or $1,200 per month for a total of $15,000 per year, strictly in cash. ... In my opinion, the evidence adduced is insufficient to enable me to change the assessments in connection with these restaurant expenses. ...

[3]      For the appellant, the issue arises in connection with a claim for an input tax credit (“ITC”). ... It is interesting to note that in 1999, this provision was amended to read “the provision of intermediary services... by a person acting in an intermediary capacity”, both of which expressions were subsequently defined as follows in Value Added Tax Act 1994:               (5) For the purposes of item 5 "intermediary services" consist of bringing together with a view to the provision of financial services—   (a) persons who are or may be seeking to receive financial services, and (b) persons who provide financial services,   together with (in the case of financial services falling within item 1, 2, 3 or 4) the performance of work preparatory to the conclusion of contracts for the provision of those financial services, but do not include the supply of any market research, product design, advertising, promotional or similar services or the collection, collation and provision of information in connection with such activities ...

He negotiated rates above the minimums by receiving $1.79 for a first waybill stop, $.79 for multiple waybill stops at the same location, $.01 per pound based on weight, $100 a day to recognize the extent of driving time and $5.75 in connection with sorting at the warehouse. [6]      It is important to appreciate that DHL establishes what they call "routes", or designated areas for a driver. ... He, or a replacement driver, would then conduct the pickups in the afternoon, return to the warehouse to unload and sort by 5:30 or 6:00 p.m. to ensure that the freight made the necessary connections. ...

He pleaded guilty to all drug offences and all offences in connection with the assumed identity. ... Garland's penalties as they pertained specifically to the employment insurance legislation, it was clear that he went to jail upon pleading guilty to offences in connection with the assumed identity. ...

Brunet incurred in connection with the project.   [4]      In assessing the Appellant, the Minister relied on the following factual assumptions, which are set out in paragraph 9 of the Reply to the Notice of Appeal.   ... Brunet tried to obtain subsidies to finance the purchase of his motor homes in connection with his previous business, but, unfortunately for him, those efforts were unsuccessful: he was never granted such a subsidy ...

Also the Appellant submits that SP Inc. furnished no benefits and no training, that the Appellant had a personal computer with software and an internet connection and a telephone at his home office, that he was not supervised and that his services were not required full-time. [12]     The Appellant referred to his office consisting of a room at his parents' home. ... However, in a recent judgment this court undertook to reject that approach, and I take the liberty of citing what I then wrote in this connection in the reasons submitted for the court. ...

The issue, then, is what deductions pursuant to subsection 62(1) of the Act are to be allowed. [15]     The moving expenses claimed by the Appellant and those allowed by the Minister of National Revenue (the "Minister") in the October 14, 2003 reassessment and subsequently (at and subsequent to the hearing) as well as an additional amount allowed by this judgment are as follows: Claimed by Appellant Allowed in October 14, 2003 reassessment Allowed subsequently Additional amount allowed by this judgment Packaging materials, (storage)                      $500 328.78 Packing and moving Household Effects:                               $9,500 NIL Temporary Lodging and Meals for 15 Days:    $6,715 198.00 Old Residence Selling Fees [Real Estate Commission:                          $3,416.20] 3,416.20 [Legal Fees:            $515.74] 515.74 New Residence Purchase Fees: [Taxes Paid for the Registration of Title:                           $1,754.10] 1,754.10 [Execution Search Fee:                                $33.00] 33.00 [Title Insurance Fee:$170.00] 170.00 [Conveyancer's Closing Fee:                                $58.85] 58.85 [Mortgage Registration and Transfer Fee:           $140.00] 140.00 [Hudac Enrolment Fee:                              $598.00] 598.00 [Legal Fees:            $792.87] 792.87 Utilities Connection Fees: [Hydro and Water Meter:                              $642] 642.00 [Bell Canada Telephone:                               $ 95] 55.00 [Rogers Cable Vision:                                $ 59.95] 59.95 Household Travel Expenses:                              $ 212.50 106.25 106.25 Totals                 $25,203.21 7,960.54 908.00 106.25 The total of the last three amounts, ie. $7,960.54 + $908 + $106.25 is $8,974.79. [16]     The Appellant should not be allowed to deduct $500 in respect of the first item, "Packaging materials", with the exception of the amount allowed by the Minister, namely, $328.78. ... However, no receipts were produced and in my opinion the amount of $198 for temporary lodging and meals allowed by the Minister is correct. [21]     The Minister properly allowed the item "Old Residence Selling Fees", to be deducted in the full amount claimed, namely $3,931.94 (ie. $3,416.20 plus $515.74). [22]     In respect of New Residence Purchase Fees, the Minister has correctly allowed a full deduction. [23]     The Minister has correctly allowed the Appellant to deduct expenses cited under Item 6, Utilities Connection Fees in full with the exception that the Bell Telephone amount has been reduced (in my opinion correctly) from $95 to $55 owing to a lack of complete and adequate receipts. [24]     In my opinion the Appellant may deduct Household Travel Expenses, in full. ...

In limited circumstances, legal fees have been held to be deductible where they are incurred in connection with the defence by a taxpayer against a charge of performing illegal actions in the operation of a business or in defence of the day-to-day methods of carrying on business. ... However, tax losses accrued by the individual before or during the bankruptcy can be used in connection with this return.   ...