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—where the taxpayer was employed in the year in connection with selling of property or negotiating of contracts for his employer, and (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. ...

The appellant had no other connection with the farming business until the Spring of 1976 when he purchased the farm in question as a going concern. ...

In assessing tax as aforesaid, he relied inter alia, upon the following findings or assumptions of fact: — the Appellant purchased 50 acres of land at RR #1, Canfield, Ontario, in 1974 for $30,000.00 cash and gave a $38,000.00 mortgage on the property in order to finance the building of a house and barn; — the Appellant commenced his farming activities in 1976: — from the time the Appellant commenced his farming activities, no profit has been earned by the Appellant from the operation of the farm; — farm losses claimed by the Appellant in computing his income for the 1976 to 1981 taxation years totalled $849.93; $6,999.79; $7,994.39; $9,760.99, $7,941.03 and $6,934.62 respectively; — the farm was maintained by the Appellant for his own use or benefit, and for the benefit of persons connected with the Appellant by blood relationship or marriage and was not maintained in connection with a business carried on for profit or with a reasonable expectation of profit; — the expenses incurred by the Appellant with respect to the farm were personal or living expenses of the Appellant and not outlays or expenses incurred to earn income from a business or property; — In the alternative, the Respondent submits that the Appellant’s chief source of income was neither farming nor a combination of farming and some other source of income, thereby limiting the Appellant to a restricted farm loss within the meaning of subsection 31(1). ...

Paragraph 66(15)(c) provides: 66 (15) In this section and sections 66.1 and 66.2, (c) “Canadian resource property” of a taxpayer means any property acquired by him after 1971 that is, (i) any right, licence or privilege to explore for, drill for, or take petroleum, natural gas or other related hydrocarbons in Canada, (ii) any right, licence or privilege to prospect, explore, drill, or mine for, minerals in a mineral resource in Canada, (iii) any oil or gas well situated in Canada, (iv) any rental or royalty computed by reference to the amount or value of production from an oil or gas well, or a mineral resource, situated in Canada, (v) any real property situated in Canada the principal value of which depends upon its mineral resource content (but not including any depreciable property situated on the surface of the property or used or to be used in connection with the extraction or removal of minerals therefrom), or (vi) any right to or interest in any property (other than property of a trust) described in any of subparagraphs (i) to (v) (including a right to receive proceeds of disposition in respect of a disposition thereof); Subsection 83A(Sa) referred to in subsection 59(1.1) relates to exploration and drilling rights; payments deductible. ...

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. ...

The question is the deductibility of certain expenses incurred by the appellant in connection with what he alleges is a business of writing and publishing a book called “The Great American Quiz Book”. ...

.: The Appellant appeals from the assessments by the Minister of National Revenue (the “Minister”) for her 1992 and 1993 taxation years whereby the Minister disallowed deductions of real estate consultant’s fees in the amounts of $19,427 and $14,003 respectively, paid by the Appellant in connection with her business. ...

It should be noted in connection with Mr. Mérette’s automobile expenses that in 1991 and 1992 most of his income came from his employment with Transtronic Inc. ...

Munro was successful in her appeals and in his judgment, The Honourable Judge Garon held that she was: [...] entitled to be reimbursed any expenses she may have incurred in connection with her appeals. ...

It has long been settled that where a taxpayer claims to have incurred business losses in connection with some activity, the Court must ascertain objectively whether that activity was carried on by the taxpayer with a reasonable expectation of profit. ...