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During the year 1960, appellant’s above-mentioned attorneys submitted accounts in a sum of $46,616.12 for their professional services in connection with the legal action against the Attorney- General of Canada with regard to Part IT of the Excise Tax Act. ... Hare, where promotion expenses incurred by coalmasters in connection with two parliamentary bills giving authority to construct a line to serve the coalfield were held to be capital expenditures.” ... M.N.R., the question in issue was as to the right to deduct, under Section 12(1) (a) of the Income Tax Act, legal expenses incurred by the appellant in connection with an application by the trustee of an estate for advice and directions. ...

In his will, after making to others a gift of some particular legacies, the testator bequeathed the residue of his estate to his wife and, to the extent that she had not disposed of it at the time of her death, to his collateral relatives and connections named in his will, who are the other appellants in the present case. ... (Here follow the names of the other appellants herein, being collateral relatives and connections of the testator.) ... Smith, both in her quality of institute and executor under the will of her late husband, the other executors under the said will, and his collateral relatives and connections who were allegedly substitutes thereunder. ...

The expenses for carrying on the business of the Wilson Company were returned at $19,396.02, most of which were apparently incurred in connection with location, survey, exploration, prospecting and assessment work, carried out on mining claims or properties. ... I propose first to discuss the issue relating to the receipt of premiums derived from the exchange of United States currency into Canadian curreney in connection with the dividends paid by Premier Gold Mining Company to the Wilson Company. ... That is the vital and difficult question for decision in connection with this branch of the appeal. ...

F. and D. 8S. re Notre Dame,’’ but it appears that this notation may have been added later when the documents were being prepared in connection with the appeal. ... The $15,000 was used in connection with expenses resulting from the serious illness in a hospital in New York and eventual death from leukemia of Sylvia Salmon Nevard, the sister of Dave Salmon and Frieda Salmon Fish. ... Certainly substantial sums were drawn from the account from time to time for her benefit in connection with these property purchases and the only benefit he ever gained from the account was an indirect one in that some $15,000 was spent on behalf of the Salmon family generally in connection with the illness of his sister. ...

Kindree whereby she was to receive a monthly salary of $200 for her services in connection with the operation of the medical clinic and $100 per month for her services in connection with the trailer court. ... The operation of the trailer court was temporary in nature and was terminated well before the taxation years here in question so that the revenues therefrom and expenditures in connection therewith do not enter into the consideration of the present appeals. ...

:—This is an appeal by the appellant from the income tax assessment for the year 1961, by which the Minister disallowed the appellant’s claim for the cost of a franchise or concession for which it allegedly had paid the capital sum of $18,000; and from the Minister’s addition, to the appellant’s income of $200 for legal expense; and for the further claim for an allowance as a deductible expense of $225 for a fee paid to accountants of the appellant and of a $200 fee paid to the solicitor of the appellant, both of which fees being incurred in connection with the acquisition of the franchise or concession. ... Counsel for the Minister concedes that the monies. paid to accountants and solicitors of the appellant in the sum of $225 and $200 respectively are proper expenses against income if, in fact, on the true interpretation of the Income Tax Act in relation to the facts of this case the appellant is permitted to charge a capital cost allowance for the payment made to Seven-Up Vancouver Ltd. in connection with this franchise. ... There is, in this case, therefore, in my opinion, direct causal connection between the issuance of the franchise, Exhibit A-1, to the appellant and the payment by the appellant to Seven-Up Vancouver Ltd. of the sum of $18,000. ...

This question is further complicated by the fact that the appellant, after the property was purchased, collected the rents and paid all disbursements in connection with the property for a period of about five or six years, all receipts going into his own personal bank account and all disbursements being made from the same account. ... In this connection, reference may be made to McLaughlin v. M.N.R., [1952] Ex. ... Certainly, it had no connection with any other investment. The total cost of the purchase of 100 shares having been approximately $4,900, I find that the $2,300 may be considered as having been used in the purchase of 46 shares thereof. ...

‘Substantial’ in this connection is not the same as ‘not unsubstantial,’ i.e., just enough to avoid the de minimis principle. ...

In calculating the amount of $35,900 owing to him, no allowance was included for the amount. to be earned in connection with the Papineau Métro Station, the amount of $3,000 appearing for Métro in the said ‘schedule being for services in connection with the tube under the station for which the work was completed. and payment made (evidence of Jean Amyot before Tax Appeal Board, Exhibit C-l, p. 26). ... The first of these was the sum of $11,110 which the deceased received in 1964 as his share of profits for work done in connection with the Sogefors contract which was completed in 1963. ... This did show amounts totalling $13,900 to be collected by him in connection with the Sogefors contract which sums it is admitted he collected. ...

Following this policy, examinations and investigations have been made in connection with the following areas:....” ... In this connection there is a Turnkey Contract with Sheldon Burden of Canada Limited. ... In this connection there are some deferred liabilities to be paid out of production and these will absorb the proceeds of the production for several months to come. ...