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Therefore, the amount of capital which the Appellant had at risk on the Prince George mortgage throughout 1993, 1994 and 1995 was greater than the capital which he had directly paid out in connection with his Mount Lehman farm. ... The losses are consistent and significant with respect to relatively modest farm revenues. [31]          There was some expert evidence on the Appellant's behalf concerning the opportunities for profit from the embryo transplant process but that expert evidence was in connection with what the Appellant was doing in Alberta around the year 2000, long after the years under appeal. ...

Burwell in connection with the renovation and preservation work by Mr. ... Burwell exercised a control over the workers in respect of the preservation of the historic nature of the property, though not in connection with how the physical work had to be, and was, conducted. ...

James') tax returns for the years under appeal and that James had no prior connection with Klayman & Company. ... She arranged to bring to Court a witness from Revenue Canada who had investigated the matter and, more importantly, she arranged to bring to Court a witness who had no connection with her client and who would, in a sense, have a contrary interest because Mr. ...

Selling a text to a non-student was sold at a price that included a margin for profit and had no connection to enrolment in a course. [16]          If a student requested a list of books for a course at the interview or enrolment stage, one was provided. ... Part of the formula for determining input tax credits provides that it is only to the extent that the supplies are consumed or used in the course of a commercial activity that input tax credits may be claimed. [22]          A "commercial activity" is defined in subsection 123(1) of the Act as follows: "commercial activity" of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individual), except to the extent to which the business involves the making of exempt supply by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individual), except to the extent to which the adventure or concern involves the making of exempt supply by the person, and (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; [23]          Pursuant to this definition a commercial activity includes "a business carried on by a person except to the extent to which the business involves the making of exempt supplies by the person". ...

In any case, I cannot make a connection between that and your situation. [124] APPELLANT: It is based on human rights. [125] THE COURT: Yes, but I cannot make a connection between that and your economic situation. [126] APPELLANT: And you do not even have the authority, you cannot even give an opinion that might wake them up a little, and say, there are a lot of people... [127] THE COURT: No. ...

Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5.        ... All factors must be considered. [76]          Test 4, work expended on or in connection with the property realized, is more applicable to land. ...

"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,... [10] This extended definition has been cited by the courts, for more than 40 years, to disallow taxpayer losses in a wide range of activities, originally in reliance on what are now paragraphs 18(1)(a) and18(1)(h) of the Income Tax Act (" Act ") which provide that no deduction may be made in respect of personal or living expenses of the taxpayer or which do not relate to producing income from a business or property.. [11] In Moldowan v. M.N.R., 77 DTC 5203, the Supreme Court of Canada articulated a number of factors to consider in determining whether a taxpayer has a reasonable expectation of profit in connection with an activity: There is a vast case literature on what reasonable expectation of profit means and it is by no means entirely consistent. ...

Young, [1993] 4 S.C.R. 3, which, inexplicably, was not cited to me by either counsel, is very clear on the subject of when costs should be awarded on a solicitor-client basis, and when they should not, and as to when they should be awarded against a solicitor personally, and when they should not. [42] Madam Justice McLachlin's reasons in that case, which are the reasons of the Court as to this issue, say this in connection with awards of costs against counsel, at page 135:... ... Shipley claims travel expenses in the amount of $710 in connection with his attendance at Toronto on the morning of Monday, November 8th. ...

I am satisfied that reasonable grounds existed for the appellant's belief that he had severed his connection with the Company as director and secretary-treasurer and concomitantly his responsibility for it when he placed his resignation in the hands of the Company's president and it was accepted by him. ... Giglio did not sever his connection with Nu-West in October 1991, although he became less "involved" with Nu-West after October 1991. ...

New LAQ hereby sells to LAQ Canada which hereby purchases all New LAQ's right, title and interest in and to the Exploration Properties for C$9,500,000, being the fair market value thereof, such amount being payable at the closing of this agreement, and LAQ Canada hereby assumes all obligations of New LAQ in connection with the Exploration Properties. 2. ... The passage in question reads as follows: AND WHEREAS by Agreement ("Asset Sale Agreement") dated June 18, 1986, Old LAQ sold to New LAQ all its right, title and interest in and to all of its asbestos-related and other mining and mill properties, building, structures, machinery, equipment, accounts receivable, inventories, all of its rights under the Joint Venture Agreement and all other assets of any kind whatsoever as at the close of business on June 30, 1986 (with the exception only of shares it held in the capital stock of Francomet), the whole including all its right, title and interest in and to the Mining Property and all buildings, structures, machinery, equipment and other assets, (except inventories) used in connection with the Mining Property (collectively "Mining Assets"). ...