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It appears the Appellant was not aware of his obligation to do so but again, he has not suggested that he sought professional, legal or accounting, advice to determine if he was under a statutory obligation to do so. [12]   Since Canadians live under a tax regime where taxpayers are expected to self-assess and self-report, I find that the Appellant must also assume responsibility for his failure to file the T1-OVP form. [13]   As detailed in the Reasons for Judgement, the Appellant filed a relief application in connection with the accumulating 1% tax and on June 19, 2015, the Minister accepted the application and waived taxes, interest and penalties of $38,193.08. While it is true that the CRA then erroneously reduced his unused RRSP contributions — which was the issue addressed in the appeal, the Minister’s decision to accept the relief application should not be interpreted as a victory — though it certainly was, that somehow shifts unto the Minister responsibility for the actions of the Appellant which the Court has described above. [14]   And the fact that the Court has sided with the Appellant in connection with the narrow issue raised in the appeal, should also not be interpreted as a victory — though it certainly was, that somehow provides the Appellant with a clean slate and again shifts responsibility for his mistakes, as noted above, unto the CRA. [15]   On the basis of this review, the Court concludes that the Appellant is and was, by a large measure, the author of his own misfortune. [16]   I now turn to the issue of costs. [17]   The Court has a wide discretion to award costs. ...

Therefore, it appears that authorization to represent the Appellant is a relatively straightforward matter. b)   Whether the proposed representative has a connection to the corporation – The pleadings and Mr. Shirazi’s affidavit indicate that he is the Appellant’s sole director, officer, and shareholder, i.e. the present application does not seek to circumvent the Rule by hiring a non-lawyer agent with no connection to the Appellant. c)   Whether the corporation can pay for counsel – The Appellant’s motion materials include a copy of an October 28, 2019 letter to the Appellant from its former counsel in which they advise the Appellant that there are outstanding legal fees in the amount of $1,928.30. ...

S.C. 1970-71-72, c. 63) (the "Act") in connection with undisclosed income of $264,300. ... Quantetics hired the appellant to provide services in connection with a research and development project for dressage horse performance and breading. ...

The context for the purpose of the interpretation of a treaty shall comprise, in addition to the text, including its preamble and annexes: (a) any agreement relating to the treaty which was made between all the parties in connexion with the conclusion of the treaty; (b) any instrument which was made by one or more parties in connexion with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty. ...

In this connection, it is perhaps of some interest to point out that in her testimony the assistant manager of the branch of the Bank of Montreal stated that she was not familiar with the Regulations of the Law Society of Upper Canada and the substance of the particular subsections to which reference will be made later. ... Morgan in connection with the negotiation and presentment of the two cheques in question. ...

The appellant did the necessary title searches ana other legal work in connection with the purchases and sales. ... For this reason much emphasis was placed by the appellant's counsel on the legal services rendered in connection with real estate transactions of the company and on the appellants work on corporate filings, maintenance of the minute book and the issue and redemption of shares. ...

We should recall in this connection the decision by Collier, J. of the Federal Court in Marvin R.V. ... Moving expenses, as permitted by subsection 62(3) do not, as I see it, mean outlays or costs incurred in connection with the acquisition of the new residence. ...

The evidence leaves no doubt the properties were not acquired in connection with the nursing home business of the corporation. ... In fact some use was made of the properties in connection with Manor's business but that was incidental to the purpose of acquisition. ...

The appellant stressed that the only point of disfavour pointed out to him by Revenue Canada had been the non-compliance with subsection 20(10) of the Act which reads: 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. ... But he might accomplish the same thing by a good swim or a game of tennis — the main point is that there is nothing to support the assertion inherent in his appeal that the convention was “in connection with the business” (subsection 20(10) of the Act so strongly relied on by the appellant). ...

In so assessing the Appellant, the Respondent assumed, inter alia, that: a) the Appellant owned and operated a yacht in Los Angeles harbour on which he lived while staying in Los Angeles, California; b) the Appellant charged to companies of which he was an officer or majority shareholder the amount of $50.00 per night for his accommodation on the yacht when he was in Los Angeles, California; c) the Appellant did not on any occasion rent the yacht to any other person; d) the yacht was not maintained in connection with a boat rental business carried on for profit or with a reasonable expectation of proft. 2.03 Penalty In the reply to notice of appeal, it was admitted that the penalty should be deleted. 3. ... They read as follows: 18. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (h) personal or living expenses of the taxpayer except travelling expenses (including the entire amount expended for meals and lodging) incurred by the taxpayer while away from home in the course of carrying on his business; (1) an outlay or expense made or incurred by the taxpayer after 1971, (i) for the use or maintenance of property that is a yacht, a camp, a lodge or a golf course or facility, unless the taxpayer made or incurred the outlay or expense in the ordinary course of his business of providing the property for hire or reward, or (ii) as membership fees or dues (whether initiation fees or otherwise) in any club the main purpose of which is to provide dining, recreational or sporting facilities for its members; 248. (1) In this Act, “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, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries. 4.02 Cases at Law Counsel for both parties referred the Court to the following cases at law: 1. ...