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The Appellant is entitled to be reimbursed any expenses she may have incurred in connection with her appeals. ... It leaves unanswered the disposition of this case where Judge Garon stated that “The Appellant is entitled to be reimbursed any expenses she may have incurred in connection with her appeals” (emphasis added). ...

Nicole Gorenko, on behalf of Gor-Can Canada Inc. understand and agree to the above proposed settlement with Revenue Canada and agree to waive any rights of Objection and of Appeal, in accordance with subsections 165(1.2) and 169(2.2) of the Income Tax Act, with respect to the assessments that will be issued in connection therewith, including any rights the companies may have under the “fairness package”. ... John Gorenko, on behalf of Alpha Leather Canada Lid. understands and agrees to the above proposed settlement with Revenue Canada and agrees to waive any rights of Objection and of Appeal, in accordance with subsections 165(1.2) and 169(2.2) of the Income Tax Act, with respect to the assessments that will be issued in connection therewith, including any rights the companies may have under the “fairness package”. ...

John Lee (Lee), to whom it was owed as a fee or commission in connection with a real estate transaction. ... The Appellant’s evidence in connection with the disputed amount is that while Tebrik was engaged in the development of land in Newmarket, Lee came to him and indicated that he was in a position to secure a parcel of land (the W land) which was then in use as a tree farm, but which was sought after by developers as having considerable profit potential. ...

Statement of Facts 1 The in (sic) years 1992 and 1994, the appellant carried on the business as a gentleman farmer and operated a horse racing business. 2 The Appellant did not have any other business and would spend much of his day attending to his horse business including the training and daily care of the horses. 3 The Appellant had farming losses of $9,733.00 for the year 1992, and $19,765.00 for 1994, which were deducted from income and were losses directly related to the farming business. 4 The Appellant maintained his racing operations with a realistic expectation of profit and submits that it was not a ‘Hobby’ and therefore the expenses incurred were in connection with the racing operation and not personal in nature. ... Statement of Facts 1 He admits the authenticity of the Notification of Confirmation dated May 27, 1997 attached to the Notice of Appeal. 2 He denies all other allegations of fact contained in the Notice of Appeal. 3 In computing income for the 1992 and 1994 taxation years, the Appellant deducted the amounts of $9,733 and $19,765 respectively, as farming losses. 4 The Minister of National Revenue (the ‘Minister’) assessed the Appellant’s 1992 and 1994 taxation years, by Notices of Assessment thereof dated June 28, 1993 and June 22, 1995, respectively. 5 In reassessing the Appellant for the 1992 and 1994 taxation years, concurrent Notices of Reassessment thereof dated June 14, 1996, the Minister disallowed the deduction of farming losses in the amounts of $9,733 and $19,765, respectively. 6 In so reassessing the Appellant, the Minister made the following assumptions of fact: (a) in the 1992 and 1994 taxation years, the Appellant reported gross farming income in the amounts of $22,950 and $2,260 respectively, arising out of the purported farming operation; (b) in the 1992 and 1994 taxation years, the Appellant claimed expenses in connection with the purported farming operation in the amounts of $32,683 and $22,025 as shown in exhibits ‘A’ and ‛B‛ attached hereto; (c) the Appellant reported gross income and expenses and claimed farming losses in prior years as follows: Year Gross Income Farming Losses 1986 N/A N/A $ 6,982 1987 $45,401 $54,042 $ 8,641 1988 N/A N/A $13,576 1989 $ 7,535 $28,966 $21,431 1990 $ 2,000 $19,361 $17,361 Year Gross Income Farming Losses 199] $20,410 $51,787 $31,377 (d) in the 1986, 1987, 1988, 1989, 1990 and 1991 taxation years, the Minister restricted the Appellant’s farm loss pursuant to subsection 31(1) of the Income Tax Act (the Acf)\ (e) for the 1995 taxation year, the Appellant reported gross farming income and expenses of $7,039 and $23,286 respectively, and claimed a farm loss of $16,247; (f) expenses in excess of the amounts allowed by the Minister were not made or incurred, or if made or incurred, were not made or incurred for the purpose of gaining or producing income from the farming operation; (g) during the 1992 and 1994 taxation years, the Appellant had no reasonable expectation of profit from the farming operation; (h) expenses in excess of the amount allowed by the Minister were not incurred for the purpose of gaining or producing income from farming, but were personal or living expenses of the Appellant. ...

Before issuing a certificate the A.P. officer must ensure that the connection to the duties is clearly established. ... Minister of National Revenue (1990), 90 D.T.C. 1668 (T.C.C.); but at least there was in that case a legal basis which I did not find in the instant appeal. 17 The Court was shown Exhibits I-2 and I-3, which are administrative policy documents, and reference was made to a administrative practice described in those exhibits, but there was no submission or argument regarding a legislative connection of any kind between this administrative policy and s. 110(1)(f) of the Act. ...

He also said that the goal of receiving dividends was too remote from the expenditures made. 14 I, in reviewing all circumstances, have concluded that the Appellant should succeed and that the legal expenses incurred in connection with the events described in these Reasons are deductible for her 1990 taxation year. ... Minister of National Revenue... 3 DTC 958 at 960 I expressed the opinion that it was not a condition of the deducibility of a disbursement or expense that it should result in any particular income or that any income should be traceable to it and that it was never necessary to show a causal connection between an expenditure or a receipt. ...

There is no direct connection between the UBC reimbursement and the Section 62 deduction, in that UBC did not indicate that the $7,000 was to be applied only to Section 62 expenses. ... Subsection 62(1) permits a taxpayer who moves from the residence in Canada at which, before the move, the taxpayer ordinarily resided to the residence in Canada at which, after the move, the taxpayer ordinarily resided, to deduct his “moving expenses” thereby incurred if the move is made in connection with the commencement at a business or employment of a particular location in Canada. 7 The Act does not define “ordinarily resided”. ...

These may be briefly set out as follows: (1) the nature of the property sold; (2) the length of ownership; (3) the frequency of other similar transactions; (4) work expended in connection with the property; (5) the circumstances that were responsible for the sale of the property; (6) motive, i.e. the intention of the purchasers at the time of the acquisition of the property. 11 While it is sometimes of assistance to be able to take a checklist such as the foregoing and go through it, and after adding the check marks pro and con coming to a decision, I do not believe that this is the only or even the proper approach. ... Except for the statement that matters were strained with the Singhs, no other concrete evidence was given in this connection. 22 As stated above, the intention of the Appellants at the time of the acquisition of the Property is a paramount factor, albeit only one of them. ...

Notwithstanding the provisions of paragraph 2, copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion pictures and works on film, videotape or other means of reproduction for use in connection With television) arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other State. 4. The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including motion pictures and works on film, videotape or other means of reproduction for use in connection with television), any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience, and, notwithstanding the provisions of Article XIII (Gains), includes gains from the alienation of any intangible property or rights described in this paragraph to the extent that such gains are contingent on the productivity, use or subsequent disposition of such property or rights. ... The terms “Products”, “Source Code” and “Object Code” shall have the meanings set forth above for all purposes in connection with this Agreement. ...

They import such meanings 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. [16]     In Gernhart v. ... This is clearly a benefit caught by 6(1)(a) as it is paid in respect to or in connection with the Appellant's employment. ...