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He has not, however, been consulted by others in this connection, except on a few occasions by contractors wishing estimates. 3.03 In December 1973, the secretary-treasurer of the company, Mr Roger Bernier, issued a notice stating that 29,843 of the 60,114 ordinary shares in the company were to be sold (Exhibit I-3). 3.04 It appears from a list of the shareholders who sold their shares and the number of preferred and ordinary shares sold in each case (Exhibit I-4) that this sale was completed in January 1974. ... These statements show that the company’s ordinary administration expenses in connection with land and buildings were about $11,000 a year. ... Is the appellant’s experience in connection with a number of liquidations enough to discharge this double burden? ...

Amounts expended by the partnership in preparing plans and performing services in connection with the construction of the “Britannia 800 Building”. ... In its 1964 taxation year, the partnership charged an amount of $14,000 to its gross revenue as costs for personal services in connection with the construction of the “12th Avenue Building” owned by 12th Avenue Building Limited. ... However, in his Notice of Objection, the appellant had stated that he did not object to the disallowance of the amounts reassessed in connection with the cost of providing services for his personal home, nor did he retract this omission in his Notice of Appeal. ...

This loss was the result of the excess of expenses over revenue which the doctor paid as his share of the expenses in connection with race horses. ... The doctor stated that he considered that his interest was not a business interest but a hobby interest and the loss incurred in connection with that horse was not a business loss. ... While initially the financial records in connection with the horses were kept by Dr Fisher, at the present time the appellant has an accountant maintaining the records. ...

All lots bought and sold in connection with this enterprise were fully serviced. ... In short, there was a pattern of business association between them in connection with the house-building business. ... Mr DeBenedictis and Mr DiSilvestro were examined for discovery in 1976 in connection with the expropriation proceedings. ...

For this reason, and this is very important, not only the fact that it is paid at regular intervals or in instalments, but it is also important to know whether there is a connection with the needs of the person in question. In this case, I can tell you, there is no connection; $10,000 was paid and this was a lump sum. ... The connection does exist, it is very relevant and the lady in question suffered from depression; you can’t cure a depression in less than two months! ...

Under the municipal law of the Province of Manitoba, the land designated as streets in the subdivision and the entire infra-structure became the property of the municipality from the main connection at the line of subdivision to the individual lot lines. ...

To be included are, and I quote from paragraph (b): Personal or living expenses (b) all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except [and the exception relied on by the agent is in subparagraph (vii)] (vii) allowances (not in excess of reasonable amounts) for travelling expenses received by an employee (other than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer if they were computed by reference to time actually spent by the employee travelling away from and it goes on to place of business and so on. ...

In connection with the expenses claimed relative to his self-employment, such of these as were disallowed by the Minister were, I consider, properly so treated and I see no occasion to interfere with what has been done. ...

The second matter which arose was in connection with the designation of a property on 19th Avenue near Markham, Ontario, as a principal residence. ...

He calculated the percentage as follows: Business percentage 5,545 J-x = 47.8%, therefore personal portion is 52.2% 11,595 The relevant sections involved are subparagraphs 6(1)(b)(v) and (vil), paragraph 8(1)(h), subsection 8(2) and section 67 of the Income Tax Act, which read as follows: 6. (1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (b) all amounts received by him in the year as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts forhisemployer, (vii) allowances (not in excess of reasonable amounts) for travelling expenses received by an employee (other than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer if they were computed by reference to time actually spent by the employee travelling away from (A) the municipality where the employer’s establishment at which the employee ordinarily worked or to which he ordinarily made his reports was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of his office or employment, 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 reasonably be regarded as applicable thereto: (h) where the taxpayer, in the year, (i) was ordinarily required to carry on the duties of his employment away from his employer’s place of business or in different places, (ii) under the contract of employment was required to pay the travelling expenses incurred by him in the performance of the duties of his office or employment, and (iii) was not in receipt of an allowance for travelling expenses that was, by virtue of subparagraph 6(1)(b)(v, (vi) or (vil), not included in computing his income and did not claim any deduction for the year under paragraph (e), (f) or (g), amounts expended by him in the year for travelling in the course of his employment; 8. (2) Except as permitted by this section, no deductions shall be made in computing a taxpayer’s income for a taxation year from an office or employment. 67. ...