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Mr Kelleher, indeed, according to the evidence had no particular connection with property business. ...

The value of a goodwill of a business is what a purchaser would be willing to give to keep the connection with which it consists, and I think that is precisely what was paid for in terms of the intangible value of both these businesses in 1973, 1974. ...

The respondent’s main argument is that in order for an expense to be deductible under paragraph 18(1)(a), there must be a link or direct connection with the taxpayer’s business. ...

However, unlike the taxpayers’ situation in Tonn, supra, there was a definite connection between the appellant’s hobby of woodworking, his expertise in the area of being able to construct and operate the 2-axis cutting machine, and the business activity he chose to pursue. ...

At page 256 the following is stated: When the material facts of the matter are examined, one finds that what transpired in 1955 and 1956 was simply this: Appellant’s numerous business connections, plus his own experience and capability, resulted in many and often large commissions being earned by him. ...

The material falls short of explaining a causal connection between the intended bankruptcy and events applicable to the 7 counts. ...

Appeal allowed. 1 1 Furlong report, section 2.7, p. 23 et seq. 2 ^Exhibit A-9 says “Coin du Pare-Brise”. 3 See Exhibits A-8 and A-9. 4 See Exhibits A-8 and A-9. 5 See Furlong report, pp. 31 and 32. 6 See in this connection two decisions referred to by counsel for the appellant: Immeubles Polaris (Canada) Liée c. ...

Apart from the gathering of raw data, all other work was done in Canada and was substantially of the same nature as that carried out in connection with the Whale and Oldsquaw Projects. ...

Minister of National Revenue, [5] Rouleau J. made reference to: the nature of the property sold; length of period of ownership; frequency of similar transactions; the work expended in connection with the property realized; the circumstances responsible for the sale of the property; the taxpayer’s intention at the time of acquisition of the asset. ...

Separate Reasons for Judgment in connection with the three corporate Appellants (the “Corporate Appeals”) were rendered on June 24, 2021 (2021 TCC 42). [2] This matter addresses costs and considers the written submissions of the parties. ...