Search - connection

This bungalow located in Florida, a vacation area, did not in itself have any connection with the company's activities. ... In summarizing the above-mentioned cases, counsel for the appellant made the following comments: Now, if we make a connection from Houle in 1983 to Dudelzac, we find that the benefit is always the first motive for the purchase of the house. ...

The other co-owners who were not appellants became participants through their personal connections with either William Bell or Fred McCullough. ... Therefore, apart from the ordinary onus of proof, the appellants here begin with an additional hurdle because of their business connection to industrial and commercial real estate. ...

And there are many forms of income which are regarded as wholly derived from property, notwithstanding that an appreciable amount of personal exertion is involved in connection with the property. At a certain stage, which in a particular case it may be difficult to define with precision, an accentuation and change of direction of this element of personal exertion may, for example, prevent income received in connection with investments from having the character of income derived from property and endow it with that of income derived from personal exertion in an investment business. ...

In many appeals where a taxpayer claims losses from a purported business, the Minister’s position is that the property in respect of which the expenses were incurred was maintained by the taxpayer for his, or his family’s, use or benefit and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit; subsection 248(1) provides that expenses incurred on such property are “personal or living expenses". ... Darnel in connection with a business carried on for profit or with a reasonable expectation of profit? ...

The question is whether the appellants’ attendance was in “in connection with the business" — that is the appellants' business of being Amway distributors. ... It did not appear to me that they needed further motivation, but even motivationally oriented convention expenses incurred “in connection with the business” should be deductible. ...

Legal Expenses, Taxes and Utilities In paragraph 2(a) of the "Grounds for appeal" the appellant states that certain costs incurred in connection with the purchase and maintenance of a property at 2700 Regina Avenue should be added to the cost base of that property. ... Capital Loss The appellant also requested in paragraph 2(b) of the "Grounds of Appeal" in the notice of appeal, that the capital loss incurred in connection with the forfeited deposit concerning the purchase of a business in the 1982 taxation year be carried forward to the 1983 taxation year. ...

It was the Court's view that it was not necessary that there be a "connection" by way of physical relationship, integration or inter-connection between the sources of income. ...

—“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. ... Analysis Having regard to the whole of the evidence, and notwithstanding counsel's innovative and persuasive analysis and submissions, I do not agree with the following positions taken on behalf of the respondent that the appellant’s appeal must fail because (a) the expenses related to maintenance of property for his mother's use or benefit, and that in any event (b) the income source was from property and not from the maintenance of property in connection with a business as is called for in subsection 248(1) "personal or living expenses”, supra, that (c) there was no reasonable expectation of profit, and that (d) the subject loss was incurred prior to the commencement of a business and is therefore not deductible. ...

In connection with the loan, the Appellant delivered his promissory note to Triarch in principal amount of $250,000 and bearing interest at 8% per annum. ... “De Wattville”), the Appellant's family holding company, and an election was made under subsection 85(1) of the Income Tax Act (the "Act") in connection with the transfer. ...

The strongest connection between the $155 and the Company is, as noted by Mr. ... Huntley Farrow that he required the $9,600 (payment for the car) for U.S. funds in connection with his trip to Florida, and it can be seen that that cheque was apparently not issued till July 13, 1982, on a date when it would appear he was already in Florida. ...