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Results 771 - 780 of 3270 for connection
TCC
Wright v. R., [1996] 1 CTC 2029 (Informal Procedure)
Although the appellant and her spouse borrowed $30,000 from the Bank of Nova Scotia, I find that these funds were used not in connection with the purchase of 74 Alderbury as alleged by the Minister, but were used to reduce the mortgage on their matrimonial home since the rate charged for the loan was less than the mortgage rate on the home. ... In allowing the appeal from the Minister’s reassessment, Garon J. made the following comments at page 2193 (D.T.C. 316): it would be unreasonable, in my view, to conclude that the appellant ceased overnight to have a reasonable expectation of profit in connection with the rental of the subject property as soon as the slump in the real estate market surfaced. ...
TCC
Bouchard v. Minister of National Revenue, [1996] 1 CTC 2239
It is in connection with this $6,500 contribution that the appellant claimed a deduction of this same amount in calculating his income for the year 1987. ... In connection with this subject see the decision of the Federal Court of Appeal in Uppal v. ...
TCC
David Krull v. Her Majesty the Queen (Informal Procedure), [1995] 2 CTC 2204, 95 DTC 206
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. ...
TCC
Terry Vango v. Her Majesty the Queen (Informal Procedure), [1995] 2 CTC 2757, 96 DTC 3240
In light of that conclusion the deductibility of the expenses claimed must depend upon whether the appellant has been able to bring himself within the provisions of subsection 8(1), and specifically paragraph 8(1)(f), which provides a deduction, in computing income from an office or employment, of: 8.(1)(f) 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(l)(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)(1), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by him. ... First, the taxpayer must be employed in connection with the selling of property or the negotiation of contracts. ...
TCC
398827 Ontario Limited and Thomas Craig Moffat v. Minister of National Revenue, [1994] 2 CTC 2047, 94 DTC 1534
The vendors represent and warrant to the purchaser as follows: (j) The company is the owner of all property and assets used by the company in connection with its business, free of all registered liens, charges and encumbrances except liens for current taxes and employee tax deductions referred to in paragraph (I) not yet due and except for any pledges, liens or encumbrances in favour of: I. ... In paragraph 3(j), the vendors have represented and warranted that any pledges, liens and encumbrances in their favour on the property and assets used by the company in connection with its business will be discharged prior to the closing. ...
TCC
Lucien Mazerolle v. Her Majesty the Queen (Informal Procedure), [1994] 2 CTC 2162, 94 DTC 1381
Even permanency of abode is not essential since a person may be a resident though travelling continuously and in such a case the status may be acquired by a consideration of the connection by reason of birth, marriage or previous long association with one place. ... R. 621 (K.B.), that: To determine whether a person has ceased to be resident of any particular place, the duration of his previous residence, his connections with that community and his interest in it are circumstances to be considered. ...
TCC
Dr. R. Hugill v. Her Majesty the Queen (Informal Procedure), [1994] 2 CTC 2221
The term ''personal or living expenses" includes, amongst other things: 248(1)(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, The issue in Moldowan, supra, was whether a taxpayer's chief source of income was either farming or a combination of farming and some other source. ... The definition of “personal or living expenses" cannot and does not suggest that expenses of property not maintained in connection with a business carried on for profit or with a reasonable expectation of profit are in all circumstances "personal or living expenses". ...
TCC
David Ragobar v. Her Majesty the Queen (Informal Procedure), [1995] 1 CTC 2364
Work expended on or in connection with the property realized. If effort is put into bringing the property into a more marketable condition during the ownership of the taxpayer or if special efforts are made to find or attract purchasers (such as the opening of an office or advertising) there is some evidence of dealing in the property. 5. ... I do not find that high degree of negligence in connection with the misstatements of business income. ...
TCC
Ronald D. Berube, Morray Investments Limited and Joanne Berube v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2655
Berube’s testimony concerning his net income for these two years and any connection therewith arising out of the company's affairs. ... He said his wife's earnings were used to pay for all personal, domestic and family matters and that all expenses paid by the company in connection with his automobile use and for promotion and insurance were solely for business purposes. ...
TCC
Dr. D.M. Karpiak Inc. And Dennis M. Karpiak v. Minister of National Revenue, [1991] 2 CTC 2702, 91 DTC 1446
For all the above reasons, the appeals in connection with rental losses for the 1984, 1985, 1986, 1987 and 1988 taxation years are dismissed. ... Expenses incurred in connection with travellers cheques amounting to $1,285 were disallowed by Revenue Canada since Dr. ...