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Results 1 - 10 of 445 for connection
T Rev B decision

D R Milne & Company Limited v. Minister of National Revenue, [1979] CTC 2294, 79 DTC 334

The benefit of the connection with insurance customers which had been built by Black over the years was intended and required to be transferred to the appellant so far as was possible. ... It is the benefit and advantage of the good name, reputation, and connection of a business. ... It is the formation of that connection which has made the value of the thing that the late firm sold, and they really had nothing else to sell in the shape of goodwill. ...
T Rev B decision

R M Helm v. Minister of National Revenue, [1977] CTC 2207

The section of the Income Tax Act which is brought into question, both by the appellant and the respondent, is paragraph 110(9)(b) and the matter at issue is whether the appellant received or did not receive any amount in connection with his employment or function with the University of Manitoba in research work, which would disqualify him under that section. ... In the opinion of the Board, the funds received by the appellant are clearly covered by either one or both sections—as an allowance or a benefit (110(9)(b)(i)), or in connection with income received from an office or employment (110(9)(b)(ii)). ...
T Rev B decision

Herwig Glander v. Minister of National Revenue, [1972] CTC 2165, 72 DTC 1151

It is the Minister’s contention: that the taxpayer incurred the expenses which gave rise to the aforesaid losses in the said taxation years as personal or living expenses in connection with the maintenance and upkeep of his 72.40- acre farm property situated in the vicinity of Orangeville, Ontario, for the use or benefit of himself, his wife and children; that personal or living expenses are not allowed as a deduction in computing income under paragraph 12(1)(h) of the Income Tax Act, RSC 1952, c 148 as amended: that, pursuant to paragraph 139(1)(ae) of the said Act, “personal or living expenses” include the expenses of a property maintained by a taxpayer for the use or benefit of himself, his wife and children and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, and that, since the present taxpayer’s above-mentioned farm property was not maintained in connection with a business of the type outlined above, the said alleged farming losses had been properly disallowed in the taxation years specified. ... So, the overall cost of the taxpayer’s country home located on Pt E 1/2 Lot 7 Con 2 W Mono Twp amounted to over $41,000 excluding the cost of the land used in connection therewith. ... Since the appellant specifically pleaded the “hobby farm” subsection 13(1) of the Act, reference should be had to paragraph numbered 4 of the Kunkel case (supra) which makes it clear that, before a taxpayer can bring himself within that provision, he must be able to establish that his farm property was maintained by him “in connection with a business carried on for profit or with a reasonable expectation of profit” within the meaning of paragraph 139(1)(ae) of the Act. 7. ...
T Rev B decision

Sylvio Marchand v. Minister of National Revenue, [1976] CTC 2024, 76 DTC 1030

Both these decisions concern brokerage fees in connection with the purchase of shares on the stock exchange. ... In this regard, the respondent maintains that there is no connection between the 4%2% costs required by the unions and the 10% interest paid on the shares. ... Nevertheless, I do not think that this passage can be taken to mean that there is no connection between the 4 /2% costs required by the union and the 10% interest payment on the shares. ...
T Rev B decision

Hugh P Barr v. Minister of National Revenue, [1972] CTC 2023, 72 DTC 1053

In his notice of appeal, Dr Barr also objected to the disallowance of a deduction claimed by him in respect of a loss of $885.43 which he allegedly sustained in the year 1965 in connection with an orchard which he operated. ... Dr Barr stated that he had done very little actual cultivation on the Naramata property and had been active chiefly in a supervisory way in connection with the Home Orchard where he and his family lived. ... In 1965 appellant suffered an operating loss of $2,939 in connection with an orchard he operated on the property surrounding his residence, of which $2,416 was designated by the Minister as being personal or living expenses and non-deductible. ...
T Rev B decision

Maria Paletta and Antonio Paletta v. Minister of National Revenue, [1977] CTC 2285

Minister of National Revenue, [1977] CTC 2285 Delmer E Taylor (orally: March 28, 1977):—These are the appeals of Maria Paletta and Antonio Paletta in connection with the 1972 taxation year. ... Counsel for the Minister has also raised a difference in terminology in the Act with respect to the Minister s responsibilities of mailing his notice, and the appellant’s responsibility in connection with instituting an appeal. ...
T Rev B decision

Douglas C Matthews v. Minister of National Revenue, [1972] CTC 2643, 72 DTC 1526

Counsel for the respondent, in his argument, contended that the expenses relating to the two farms were not incurred in respect of properties maintained in connection with a business carried on with a reasonable expectation of profit. ... Subparagraph 139(1)(ae)(i) speaks of the expense of properties not maintained in connection with a business carried on with a reasonable expectation of profit. ...
T Rev B decision

William H White v. Minister of National Revenue, [1972] CTC 2033, 72 DTC 1036

Dr White testified that he owned his own car, which was used scrupulously for professional calls in connection with his medical and surgical practice. ... The same situation prevailed in connection with the hospital at Summerland, where his services were also in regular demand. ... This phone is used by the doctor in connection with his practice and also by his family in general. ...
T Rev B decision

John G Critchley v. Minister of National Revenue, [1983] CTC 2365, 83 DTC 278

In so reassessing the Appellant, the Respondent found or assumed: (a) the facts hereinbefore pleaded; (b) that the Appellant has claimed as moving expenses, the connection of certain appliances and services namely, a television, a telephone and electricity/- water totalling $42.65. ... Moving expenses, as permitted by ss 62(3), do not, as I see it, mean outlays or costs incurred in connection with the acquisition of the new residence. ... In my view, these kinds of expenses embrace only those related directly to the sale of the former home, and not all the expenses or costs incurred in connection with the sale of his old residence. ...
T Rev B decision

Jacques St-Germain v. Minister of National Revenue, [1983] CTC 2038, 83 DTC 36

In computing his income for the 1979 taxation year, the appellant claimed the sum of $15,150 as a deduction for legal expenses incurred in 1979 in connection with this matter. 4. ... In Holland Paper Co Ltd (supra), the Exchequer Court allowed legal expenses in connection with a criminal prosecution of a similar nature, but where the accused had been convicted. ... However, they are not expenses in connection with an action against his employer related to his contract of employment, as an action for wages would be. ...

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