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When land has been purchased at a tax sale, the legally registered owner has a period of 12 months in which to repay the taxes plus, I think the evidence was, interest or some other terminology, at 10 per cent to make up for the prospective purchaser having had his money tied up for that period of time. 6 It is clear that Doral, at the time it made this substantial advance to East End in January 1968, had, according to the evidence that has been adduced, every reason to believe that a substantial and large income- producing future lay ahead as a result of its connection with East End. ...

In a letter of October 29, 1971 (Exhibit A-8) A & W's solicitors, on the assumption that Richfield Real Estate Ltd and Mr Brad Calvin, who had been acting on behalf of A & W had business interests with the appellant company, and particularly in connection with the proposed sale with Trojan, stated that A & W was no longer prepared to grant possession of the McLeod property unless a statutory declaration was signed by Messrs Calvin and Kitzul that no such business interests existed between them. ...

The evidence also shows that the appellant was not allowed to practise ophthalmology other than in connection with his teaching at the clinic. ...

Minister of National Revenue, [1978] CTC 2541, [1978] DTC 1398 Delmer E Taylor:—This is an appeal against an income tax assessment for the year 1972 wherein the Minister of National Revenue assessed to tax the recaptured capital cost allowance in connection with a deemed disposition of depreciable property. ...

Argument Counsel for the appellant quoted an explanation provided by. the Department of National Revenue in connection with the assessment: A capital loss is realized on sale of Shares, bankruptcy of the company, surrender of the charter, or cancellation of the charter by ‘the Province and as none of these events occurred during 1975, the capital Joss is not allowable for the year. ...

In June 1973, I severed my connection with the Company, and the shares were sold the following year. ...

Counsel for the Minister agreed that the Board’s decision would only relate to whether or not the alleged “inventory” of leased cars fitted the requirements of the Act on a basis equivalent to the inventory of new and used cars, as portrayed in this case, and this case only. lt was common ground between the parties that no funds of the company relative to the deduction sought had been laid out, nor had any obligation in connection with it been taken on by the company, other than the original purchases of automobiles which would be accounted for in the normal course of events. ... It might well be argued that utilizing paragraph 20(1)(gg) as one would deal with any other calculated allowance in connection with a reserve — deducting it from income one year and bringing it back in the next, if necessary — would support the contention of counsel for the appellant that the allowance is permissible year after year, and it could be in accord with the decision in T Bar B (supra). ...

No expenses in connection with the Camaro were claimed in computing the appellant’s income. 3.09 Two of the invoices filed in support of automobile expenses related to the Camaro: one dated July 21, 1971 and one April 25, 1971. ... Expenses in connection with a snowblower and garage 3.11 The appellant also claimed depreciation on a snowblower used to clear the entrance to a garage he had rented, presumably not far from his residence. ...

Amounts to be included as income from office or employment (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: (a) Value of benefits—the value of board, lodging and other benefits of any kind whatever (except the benefit he derives from his employer’s contributions to or under a registered pension fund or plan, group sickness or accident insurance plan, private health services plan, supplementary unemployment benefit plan, deferred profit sharing plan or group term life insurance policy) received or enjoyed by him in the year in respect of, in the course of or by virtue of an office or employment; (b) Personal or living expenses—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 (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. ... Definitions (1) In this Act, “Personal or living expenses’’—“personal or living expenses” includes (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, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries. 4.2. ...

Section 248 of the Act reads as follows: “farming” includes tillage of the soil, livestock raising or exhibiting, maintaining of horses for racing, raising of poultry, fur farming, dairy farming, fruit growing and the keeping of bees, but does not include an office or employment under a person enagaged in the business of farming; “personal or living expenses” includes (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, (b) the expenses, premiums or other costs of a policy of insurance, annuity contract or other like contract if the proceeds of the policy or contract are payable to or for the benefit of the taxpayer or a person connected with him by blood relationship, marriage or adoption, and (c) expenses of properties maintained by an estate or trust for the benefit of the taxpayer as one of the beneficiaries: 4.02 Cases of Law The counsel for both parties referred the Board to the following cases of law: 1. ... 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. ...