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Thus, the Appellant borrowed the money on a credit card to make the donation. [18]     The Appellant is a member of the Armenian Catholic Church, which she supports but did not claim, in either 1994 or 1996, any donations thereto. [19]     The T1 tax return for 1994 shows that the Appellant's taxable income was $29,202 and claimed a tax credit for a charitable gift of $5,000 to Or Hamaarav Sephardic Congregation, a Jewish organization which she had absolutely no connection to. [20]     The T1 tax return for 1996 shows that the Appellant's taxable income for 1996 was $18,533 and that she donated $4,500 to Abarbanel S. Learning Centre, again a Jewish organization, which she had no knowledge of, or connection thereto. [21]     She claimed that the possibility of making donations was brought to her attention by her tax preparer, namely Mourad Halajian, who was her brother-in-law. [22]     When the Appellant was asked who she gave the cheque to and who gave her the receipt, she simply stated: "I cannot recall. ...

The question that the Court must answer here is whether the expenses that the Appellant deducted in connection with the property were made for the purpose of deriving income from property, and whether these expenses were personal or living expenses of the Appellant within the meaning of the Income Tax Act (the "Act"). [2]      The Appellant purchased the property, located in North Hatley, Quebec, in May 1999 for the sum of $58,000 and took possession of it in July of that year. ... Delorme's son vacated the property, it sold for $120,000. [8]      The Minister refused the deduction of rental losses because the expenses that constituted these losses had not been incurred in order to produce income, but were personal or living expenses, and because paragraphs 18(1)(a) and 18(1)(h) of the Income Tax Act prohibited the deduction of such amounts. [9]      I conclude that the appellant did not establish, on a balance of probabilities, that he purchased and held the property with the intention of deriving rental income from it, and that he did not establish that the expenses were not personal and living expenses within the meaning of section 248 of the Act, which reads in part as follows: "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 common-law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, [10]     Although the Appellant stated that he could earn $10,000 a year in rent from the property if he rented it during holiday periods, it was clear that major work had to be done on the house before this would be possible. ...

Fawaz and indicated that a Notification in connection with the Reassessments of the Applicant's 1992, 1993 and 1994 taxation years was issued on the 9th day of November 2000. ... There was no obligation on him to look beyond that information. [17]     In connection with the address used by the Minister it should be noted that Mr. ...

Warren's business. [6]      By letter dated the 28th day of August 2002 Michael Taylor, counsel for the Respondent, wrote to the Tax Court in connection with the comments made by Mr. ... Taylor referred me to several Court decisions. [7]      In connection with the claim by counsel for the Appellant that the Appellant's liability should be reduced by $33,500.00 to reflect the fact that the entire proceeds from the mortgage went to Mr. ...

(admitted) (d)         The respondent informed the appellant that the employment held by a person in the government of a province in connection with an election or referendum was not insurable if that person did not regularly hold employment with that employer and held that employment for less than 25 days. ... (c) employment of a person by Her Majesty in right of Canada, the government of a province, a municipality or a school board in connection with a referendum or election to public office if the person (i) is not regularly employed by that employer, and (ii) is employed by that employer in that employment for less than 25 days. [20]     The evidence showed that the appellant did not hold regular employment with this payer and that she held employment for less than 25 days. [21]     For the purposes of the Employment Insurance Act, Parliament saw fit to make this exception and to exclude this employment from insurable employment. [22]     Parliament allows that regulations be made to exclude certain employments from insurable employment. ...

Since the patients belonged to the clinic, and she had few expenses in connection with her duties there, she had no chance of profit or risk of loss. ... She also had no risk of loss in connection with her work at the clinic since her only expenses were her association fees and liability insurance. ...

(the "Employer"); (b)            the Appellant was principally employed in selling or leasing automobiles; (c)            an automobile owned by the Employer was made available by the Employer to the Appellant; (d)            the Employer has acquired one or more automobiles; (e)            the cost of the Employer owned vehicle in the 1995, 1996 and 1997 taxation years was determined by dividing the cost to the Employer of all new automobiles acquired by the Employer in the year for sale or lease in the course of the Employer's business by the number of automobiles acquired resulting in the following amounts:      1995     1996     1997 Average Cost of New Vehicles Purchased $23,086.00 $24,556.00 $23,340.00 Provincial Sales Tax 1,616.02 1,718.92 1,633.80 Cost including PST $24,702.02 $26,274.92 $24,973.80 (f)             the automobile was made available to the Appellant for 365 days during each of the 1995, 1996 and 1997 taxation years; (g)            the Appellant was required by the Employer to use the automobile in connection with or in the course of the office or employment; (h)            all or substantially all of the distance travelled by the automobile during the days the automobile was available were not made in the course of the office or employment with the Employer. [3]            The Appellant is a shareholder in Westward Ford Credit Ltd., an automobile dealership located in Portage la Prairie, Manitoba. ... The entitlement to reduce the standby charge in this fashion is only available where the automobile is used all or substantially all of the time in connection with the employment. ...

Moving expenses, as permitted by ss. 62(3), do not, as I see it, mean outlays or costs incurred in connection with the acquisition of the new residence. ... It does not fall within the meaning of legal fees in connection with the purchase of a new residence. ...

Paragraph 18(1)(h) specifically limits the deductibility of personal or living expenses, which are defined in subsection 248(1) of the Act to exclude expenses in connection with a property unless it is maintained in connection with a business carried on for profit or with a reasonable expectation of profit. [8] In Moldowan v. ...

They import such means as “in relation to”, “with reference to” or “in connection with”. The phrase “in respect of” is probably the widest of any expression intended to convey some connection between two related subject matters. [8]              In referring the Appellant’s claim back to another Hearings Officer, the Workmen’s Compensation Tribunal directed that the Appellant’s “pain resulting from the injury” was to be rated (See exhibit A-1, page 2 paragraph 2). ...