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., at page C.T.C. 312-13, 1173): Different considerations apply to the remaining items of expense, namely the legal expense for 1950, incurred for legal advice for the benefit of certain shareholders, and the stock transfer expense, listing fees for common stock, printing and stationery in connection with the annual meeting of shareholders and proxy expense. ... Sandilands said, must be incurred by a corporation whose shares are listed on the stock exchanges, but they are incurred in the course of the appellant’s dealings with its own shareholders as shareholders and in connection with the administration incident to the capital structure and arrangements of the appellant, rather than in carrying out activities which form any part of the business or process or function or means by which the appellant’s income is gained or produced. ...

Would the business loss claimed in connection with the partnership in 1986 unduly or artificially reduce the appellants’ incomes within subsection 245(1) of the Income Tax Act? ... See also paragraph 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. ...

For her part, counsel for the respondent noted that the taxpayers' testimony as to their intent must be borne out by the facts and that, in this connection, it is necessary to look at their conduct as a whole in relation to the various tests developed by the courts. ... In this connection, there is the following comment by Cattanach, J. at page 56 (D.T.C. 5039-40) of this decision: If the Minister has failed to allege as a fact an essential ingredient to the validity of the assessment under the applicable statutory provision there is no onus on the taxpayer to disprove that fact for the assumptions which were made do not of themselves support the assessment. ...

In that connection I would refer to the following: Exclusion of Witnesses — Carswell, Toronto, (1982) Report of the Federal/Provincial Task Force on Uniform Rules of Evidence — Chapter 22 at 277. ... This triangular-shaped piece of property was directly adjacent to a connection in the traffic circle part of the Trans-Canada Highway. ...

Purchaser agrees that no documents or notices thereof shall be registered by it in connection with this transaction. 2. ... Assignability Neither this agreement, nor any claim against Shell arising directly or indirectly out of or in connection with this agreement shall be assignable by the Purchaser or by operation of law, without the prior consent of Shell. 12. ...

The Minister disallowed the deduction of rental losses incurred in connection with an apartment situated in Miami Beach, Florida. ... Stein filed his tax returns for 1986 and 1987 claiming net rental losses in connection with the Tower House condo. ...

In connection with this visit to the taxidermy shop, Mr. Fazekas included a fee of $2,000 paid to the taxidermist for one of his animal trophies and claimed it as an “advertising expense”. ... They do not have the required business connection. Furthermore, Mr. Fazekas was not a veterinary who, as such, could become an expert on antelope, although I recognize that his expertise in endocrinology might be useful in helping his son in his research on those animals. ...

The Lender shall not (i) be entitled to sue or commence any action or other proceeding against the Borrower, or (ii) be entitled to seek a judgment, execution or other process against the Borrower, in respect of the collection of the Indebtedness, except, in each case, for the purpose of, or in connection with, realizing on the Collateral. *** 3.1 The Borrower hereby acknowledges and agrees that the Lender shall engage at the Borrower’s expense one or more duly qualified investment advisers, including discretionary portfolio, managers, to assist in the investment of the Collateral with a view to meeting the expectations of the parties as set forth above and in furtherance thereof to maximizing the capital appreciation of the Collateral prior to the Due Date while at the same time minimizing income thereon taxable in respect of any period prior to the Due Date. ... For greater certainty, the Lender’s obligation hereunder shall be determined on a cumulative basis, so that in the event that a taxable loss results to the Borrower for tax purposes in any year then the Lender’s obligation to distribute any amount thereafter shall be limited to the extent by which taxable income in subsequent years exceeds the amount of loss so resulting. *** 4.1 The Borrower acknowledges and confirms that: (a) the Lender does not, by reviewing this Application, make any commitment to the Borrower to make the Loan; (b) except as expressly set forth herein the Lender does not make any representation or warranty to the Borrower whatsoever with respect to the Pledge or the tax effect thereof, or otherwise; (c) the Lender has no responsibility for, is not and has not been associated with, and does not express any opinion with respect to any representations, warranties, declarations or undertakings made by any other party in connection with the Loan or any other transaction; (d) the making of the Loan by the Lender to the Borrower is a transaction completely separate from and independent of the Pledge and any other transaction relating thereto and the Borrower will be irrevocably obligated to the Lender for payment of the Indebtedness without regard to any issues which may arise between the Borrower and any other person or persons; (e) the Lender will be obliged to exhaust its recourses in respect of its security before looking to the Borrower for payment; and (f) nothing contained herein or in any other instrument will be interpreted so as to oblige the Lender to extend any time for payment of the Indebtedness under any circumstances. ...

Counsel for the respondent argued that the $4,263.93 in expenses with respect to the immovable on Dorion Street must be added to the cost of the immovable and taken into account in connection with the disposition in 1989. ... It is my view that the evidence shows no connection between the amounts borrowed and the money loaned in the appellant’s money lending business. ...

Issue in dispute [11] This appeal deals with the Appellant’s entitlement to the Rebate, and more particularly, whether in connection with the Property, the conditions in paragraphs 256(2)(a) and (c) of the Excise Tax Act, RSC 1985, c E-15, as amended (Act) and paragraphs 46(2)(a) and (b) of the New Harmonized Value-Added Tax System Regulations, No. 2, SOR/2010-151 (Regulations) have been satisfied. [12] In the event that all conditions are met, the appeal should be allowed. ... Only one exhibit with one document relating to the purchase of the vacant land, two quote sheets, and two invoices for a total amount of $14,166.36 was filed to justify the payment of construction bills for the house. [27] No exhibit was filed by the Appellant contemporaneous with the Property moving date (September 15, 2019), neither in connection with the 4525 Osaka Circle, Windsor, Ontario they allegedly left to live in the Property. ...