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    [22]     The appellant claims a deduction for legal expenses paid in 2003 in connection with the conduct of the appeal of the retrial ... In the facts before Justice Bowie, the legal expenses were incurred in connection with the appeal of the first conviction. ...

Exhibit A-3 is a copy of a different invoice dated November 16, 1994 from Deacur & Co. to the Appellant in the amount of $30,621.26 for services in connection with documenting the 1994 SR&ED expenditures and claiming the corresponding ITCs ... I conclude that a “qualified expenditure” must be incurred in connection with ongoing research and development, and not incurred after-the-fact because research and development have already taken place. ...

  [2]      The Appellant's position includes that the $74,000 expense was incurred solely in connection with the consequences of his resignation from Lafferty, Harwood & Partners Ltd. ...   [5]      Further, the relevant parts of paragraph 8(1)(f) of the Act read as follows: 8(1)      In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may be reasonably regarded as a applicable thereto               (a)        …   (f)        where the taxpayer was employed in the year in connection with selling of property or negotiating of contracts, for the taxpayer's employer and,   (i)         under the contract of employment was required to pay the taxpayer's own expenses,   (ii)        …   (iii)       was remunerated in whole or in part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and...   ...

While the existing case law deals with interest income derived from cash investment certificates as opposed to royalty income derived from mineral interests, money cannot be equated with goods and services themselves and therefore it is logical that in order for interest to be considered active business income the underlying cash must be shown to have a close connection with the business. ... As appellants counsel observed, the very essence or nature of money, being a simple medium of exchange, mandates an identifiable connection with active business income. ...

No connection was made between the payment of these expenses in 1983 and the deductions claimed in 1981 and 1982 for soft costs. ... In this connection we may recall the observations of Dickson, C.J. of the Supreme Court of Canada in Bronfman Trust v. ...

Calvano is entitled to moving expenses that consist of costs of $18,376 covering realtor's commission, legal fees and a mortgage repayment in connection with the sale of the Brampton property in May 1996, and costs of $6,340 covering legal fees and taxes in connection with the purchase of the Port Moody property. [18]     The relevant provisions are subsections 62(1) and 62(3) and I will just read the pertinent parts of subsection 62(1) for now: 62(1)     Where a taxpayer has, at any time, commenced (a)        ... to be employed at a location in Canada,... and by reason thereof has moved from the residence in Canada at which, before the move, the taxpayer ordinarily resided,... to a residence in Canada at which, after the move, the taxpayer ordinarily resided,... so that the distance between the old residence and the new work location is not less than 40 kilometres greater than... ...

In a leading Canadian text on income tax law the author notes [4]: If a taxpayer incurs a debt in connection with his acquisition of a fixed asset and the debt is later forgiven in whole or in part, the forgiveness is not a revenue gain to him. If a debt was incurred in connection with the acquisition of inventory in a particular taxation year and is forgiven, in whole or in part, in the same year, the forgiveness will probably be treated as business revenue, regardless of what the creditor’s motive was in forgiving a debt. ...

Adams is able to satisfy the eligibility criteria set out in paragraphs 122.3(1)(a) and (b), the relevant portions of which read: Deduction from tax payable where employment out of Canada. (1)         Where an individual is resident in Canada in a taxation year and, throughout any period of more than six consecutive months that commence before the end of the year and included any part of the year (in this subsection referred to as the "qualifying period") (a)         was employed by a person who was a specified employer, other than for the performance of services under a prescribed international development assistance program of the Government of Canada, and (b)         performed all or substantially all the duties of the individual's employment outside Canada (i)          in connection with a contract under which the specified employer carried on business outside Canada with respect to (A)        the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources,... [11]     The Crown argued that even if Cheyenne was Mr. ... Adams was resident in Canada throughout the "qualifying period" in 2002 and was employed by Cheyenne, a specified employer, as a drilling supervisor (and therefore, "other than for the performance of services under a prescribed international development assistance program of the Government of Canada") and as such, performed his duties in the Algerian oilfields in connection with a contract under which Cheyenne as the contractor of BP Exploration (In Salah) Limited, carried on business outside Canada with respect to the exploration for or exploitation of petroleum. ...

In his returns of income for those years the appellant sought to deduct costs claimed to have been incurred by him in connection with the construction of a building on lands described as 1948 McKercher Drive in the City of Saskatoon. ... Furthermore, since the appellant was not the owner of the building in the 1981 taxation year, he is not entitled to the deduction of any capital cost allowance in connection with the building in that year. ...

Every director and officer of a corporation shall exercise the powers and discharge the duties of his office honestly, in good faith and in the best interests of the corporation, and in connection therewith shall exercise the degree of care, diligence and skill that a reasonably prudent person would exercise in comparable circumstances. ... I am satisifed that reasonable grounds existed for the appellant's belief that he had severed his connection with the Company as director and secretary-treasurer and concomitantly his responsibility for it when he placed his resignation in the hands of the Company's president and it was accepted by him. ...