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In this connection counsel relied on s. 118.1(1) and s. 118.1(2) of the Act and ss. 3500 and 3501 of the Income Tax Regulations (“the Regulations”). ...

In connection with Mr. Lanctôt’s practice of dentistry, it should be noted that he sold his own clinic in 1987 and that from that year onward he paid the rental and administrative costs by giving up 40 percent of his fees to the clinic where he worked. ...

That the Plaintiffs are entitled to be indemnified by Westminer against all costs, charges and expenses reasonably incurred, and to be incurred in connection with the Ontario Action. ...

In connection with this argument, Mr. Kenny submits that the R.C.M.P. is, in effect, a third party and that the actual employer was the Treasury Board and consequently, section 231 is applicable. ...

In the fall of 1990, the Appellant was approached by a corporation in Edmonton, specifically, the Sherritt Corporation, and offered a position in that city in connection with his scientific background. ...

Canada, 99 DTC 5117 (para. 21), “a deduction cannot be so far removed from its corresponding income stream as to render its connection to the anticipated income tenuous at best.” ...

.; (e) in return for the payment of $42,000 by Les entreprises Loma Ltée the appellant gave his personal residence as security; (f) on October 6, 1989 a cheque for $42,000 from Les entreprises Loma Ltée was deposited in the appellant's personal account, less a $1,000 cash withdrawal; (g) on the same day a cheque for $35,000 made out to Communications Daniel Morency Inc. was deposited in the company's account by the appellant; (h) the amount of $35,000 was recorded in the books of Communications Daniel Morency Inc. as an issue of capital stock to the appellant; (i) as a consequence of services rendered by Communications Daniel Morency Inc. three invoices dated August 18, October 5 and November 20, 1990 for a total of $42,000 and in Daniel Morency's own name were sent to Les entreprises Loma Ltée; (j) the appellant failed to report the sum of $42,000 as income in his tax return for 1990; (k) Communications Daniel Morency Inc. failed to report in its income tax return for 1991 the sum of $42,000 deriving from the contract between it and Les entreprises Loma Ltée, even though Communications Daniel Morency Inc. had incurred expenses in connection with this contract and claimed them as business expenses; (l) as the appellant knowingly or under circumstances amounting to gross negligence made an omission in his tax return for the 1990 taxation year by not reporting the sum of $42,000 in his income for that year, a penalty in the amount of $5,573 has been imposed pursuant to s. 163(2) of the Income Tax Act. 13 Subparagraphs 8(a) to (g), (i) and (k) of the Reply were admitted. ...

Ignorance of the Act is not a valid excuse and the absence of accounting records tends to show a certain indifference which constitutes blameworthy negligence, especially in a tax system based on self-assessment by the taxpayer. 11 This carelessness and disregard of Tier tax responsibilities was confirmed by her obviously deliberate failure to report the tips she received in connection with her employment. 12 In tax law this is gross negligence which fully justifies the application of the penalties prescribed by the Act. ...

In 2015 he engaged his mother-in-law, who lived in the same household, to do certain work using a home laptop computer with VPN connection to his office files. ...

In particular, the Court relied on Mylan where Stratas JA made the following comments in connection with a request that one proceeding be held in abeyance pending the outcome of a second proceeding: [5]...When we do this, we are exercising a jurisdiction that is not unlike scheduling or adjourning a matter. ...