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It provides: Notwithstanding paragraph 18(1)(b), there may be deducted in computing a taxpayer’s income for a taxation year from a business an amount paid by the taxpayer in the year as or on account of expenses incurred by him in attending, in connection with the business, not more than two conventions held during the year by a business or professional organization at a location that may reasonably be regarded as consistent with the territorial scope of that organization. ... In order to succeed the appellant must also establish that the expenses incurred in attending the convention at Monte Carlo were in connection with the business of the members of the partnership within the meaning of subsection 20(10). ... Consequently, the expenses incurred were not in connection with business within the meaning of subsection 20(10) of the Act. ...

. — where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his employer's place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), or (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by him. ... While subparagraph 6(1)(b)(v) speaks of an employee employed in connection with the selling of property or negotiating of contracts for his employer, there can be many taxpayers so employed who are on fixed salaries without com- missions. While in the opening words of paragraph 6(1)(f) reference is made to a taxpayer employed in connection with the selling of property or negotiating of contracts for his employer these words relate to commission salesmen because they are conjunctively tied in with the words "was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sale made or the contracts negotiated? ...

Subparagraph 40(2)(f)(ii) of the Income Tax Act (“the Act”) provides that a taxpayer’s gain from the disposition of a right to receive an amount as a prize in connection with a lottery scheme is nil. Subsection 52(4) states that where any property has been acquired by a taxpayer at any time after 1971 as a prize in connection with a lottery scheme, he shall be deemed to have acquired the property at a cost to him equal to its fair market value at that time. ... First it is said that paragraph 40(2)(f) of the Act, which I have already mentioned and which is designed to ensure that an amount received as a prize in connection with a lottery scheme is not taxable as a capital gain, disposes of this appeal in the appellant’s favour. ...

The Minister queries whether the expenses of a property were maintained by the taxpayer for the use of the taxpayer and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. If the property was not maintained in connection with a business carried on for profit or with a reasonable expectation of profit then the Act, at subsection 248(1), provides that the expenses of that property are personal or living expenses; personal or living expenses are not deductible by a tax payable in computing income: paragraph 18(1)(h). ... See also s. 139(1)(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. ...

Amounts to be included as income from office or employment. (1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (b) Personal or living expenses — all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer, (vi) reasonable allowances received by a minister or clergyman in charge of or ministering to a diocese, parish or congregation for expenses for transportation incident to the discharge of the duties of his office or employment, (vii) reasonable allowances for travelling expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the: selling of property or the negotiating of contracts for the employer) from the employer for travelling away from (A) the municipality where the employer’s establishment at which the employee ordinarily worked or to which he ordinarily made his reports was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of his office or employment, 8. ... (vii) reasonable allowances for travelling expenses (other than allowances for the vise of a motor vehicle) received by an employes: (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from (A) the municipality where the employer’s establishment at which the employee ordinarily worked or to which he ordinarily made his reports was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of his office or employment, Subparagraph 6(1)(fe)(vii) is applicable to the appellant as regards the application of paragraph 8(1)(/t) because he did not receive reasonable allowances for accommodation expenses. ...

(vii) reasonable allowances for travel expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from (A) the municipality where the employer’s establishment at which the employee ordinarily worked or to which the employee ordinarily reported was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of the employee’s office or employment, (vii.1) reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment,... [11] The above wording has been in effect since 1994 and applies to the 1990 taxation year and later. [6] The retroactive amendment in 1994 specifically deleted the previous wording of “allowances (not in excess of reasonable amounts)” [7] from both subparagraphs 6(1)(b)(vii) and (vii.1) and replaced it with “reasonable allowances”. [12] In explanation of the amendment, the May 30, 1991 Department of Finance Technical Notes say: These paragraphs are amended, applicable to the 1990 and subsequent taxation years, to provide that reasonable allowances in respect of travelling expenses and motor vehicle expenses will be excluded in computing the income of an individual from an office or employment. ... Here, Burnaby City Hall has no connection to the employer’s establishment so the allowance received by Mr. ...

Dussault J.T.C.C. [1] The appellant is challenging an assessment, notice of which was dated April 29, 1997, for tax on income from Canada of non-resident persons (Part XIII) for the 1996 taxation year. [2] The appellant also disagreed with the amounts claimed by the Minister of National Revenue ("the Minister") pursuant to a judgment of this Court on December 3, 1997 dismissing his appeals from assessments made for the 1991 to 1995 taxation years inclusive, in connection with the seizure by the Minister of a total amount of $26,638.02 from a bank account on May 23 and June 4, 1997. [3] This second point is essentially one of collection of money owed pursuant to a judgment, not an appeal from an assessment. ...

  [2]      The appellant declared bankruptcy on February 22, 2000, and subsequently received a retroactive lump-sum payment of $9,725.89 in employment income, $806.40 as a retiring allowance and $6,465.57 in interest in connection with this lump-sum payment. ...

Bodker in connection with the appeal but these appointments were not kept. ...

  [5]      Various assessment notices were issued by the Canada Customs and Revenue Agency ("CCRA") to the Company in connection with GST ...