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In 1986, the appellant commenced the business of developing prototypes of, subsequently producing, and maintaining, machine tools to be used in connection with computer applications software. ... S.C. 1970-71-72, c. 63) (the"Act") which includes as" personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the tax- pe for his own use and benefit, and not maintained in connection with a ess carried on for profit or with a reasonable expectation of profit. ...

The subject-matter of the realization — In this connection the authors comment: “... property which does not yield to its owner an income or personal enjoyment merely by virtue of its ownership is more likely to have been acquired with the object of a deal than property that does.... ... Supplementary work on or in connection with the property realized — The authors' comments under this heading read: If the property is worked up in any way during the ownership so as to bring it into a more marketable condition; or if any special exertions are made to find or attract purchases, such as the opening of an office or large scale advertising, there is some evidence of dealing. ...

Saikely’s evidence was needed, among other things, to show the connection between the moneys from her parents and her husband. ... The lack of precision, the lack of connection, the lack of records, the lack of documentation, the absence of essential witnesses and, quite frankly, the general evasiveness of the appellant's testimony leads this Court to the conclusion that the appellant has not discharged the onus placed upon him. ...

As I understand it, the substantive point being made by counsel is that these appellants should have known at the time the expenditures of some $159,600 had not been made by the corporation filling out the designation, (because there was no such corporation during the period of making such expenditures) and that therefore they were instantly incurring a tax liability in connection therewith for the corporation initially but not for themselves. ... The evidence established that all the amounts stated by the respondent came from business funds, and the use appeared to be in connection with demands of the shareholder Michel Seguin rather than for legitimate business purposes. ...

Subsection 18(2) limits the deduction of interest expenses and property taxes incurred in connection with undeveloped land. ... Therefore, the transaction should be treated as an adventure in the nature of trade, and the foreign exchange loss sustained in connection with it should be treated as an income loss. ...

It is in connection with tree farming, however, that the appellants claim the right to deduct their losses under section 31 of the Income Tax Act. ... Wong testified that the Black Gold Tree Farm suffered further losses in subsequent years as follows: 1986 $18,724 1987 22,406 1988 13,500 (approximate) She also listed the following capital outlays in connection with the tree farm: 1979 land $53,900 1980 equipment 12,946 1981 equipment 9,464 1982 equipment and building 29,866 1983 equipment and building 12,955 1984 equipment and fencing 12,500 1985 equipment 4,374 1986 equipment and fencing 7,828 1987 nil 1988 fencing and sprayer 2,000 1989 tractor 18,000 The total of these capital outlays is $163,833. ...

Also, a nexus or connection to the appellant's employment income can be strongly inferred as the actual and frequent delivery of the subject legal services bore a rational and direct connection to the remuneration earned and received by her. ...

In my view, this term 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. ... In brief, there was mentioned, (1) the nature of the property, (2) the length of period of ownership, (3) the frequency or number of other similar transactions by the taxpayer, (4) work expended on or in connection with the property, (5) the circumstances that were responsible for the sale of the property, and (6) the motive of the taxpayer at the time of acquiring the property. ...

In this connection, the following passages in the transcript of the evidence are significant: Q. ... M.N.R., [1989] 2 C.T.C. 2069; 89 D.T.C. 331 where the learned judge came to a different conclusion on the tax treatment of certain gains made in connection with the purchase of a scientific research tax credit debenture. ...

There is to be a nexus or significant relationship between the employee's principal employment duties with that of their sales activities, and that that relationship and connection is to be more than merely incidental or ancillary. ... Szostak, Clarke and Davies were simply too remote or ancillary in nature to satisfy the principal employment connection to sales activities. ...