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These include items such as the nature of the property sold; the length of period of ownership; frequency or number of other similar transactions by the taxpayer; work expended on or in connection with the property realized; circumstances that were responsible for the sale of the property; and motive. [21]     He submitted that in the present appeal, the most relevant factors are the nature of the property, i.e. raw land, in the form of beach-front property, in an area where the interest in such property is strong, and the extremely short holding period, both of which point strongly to the disposition of the property being on income account. ...

In other words, objective evidence of a connection between data purchase and actual exploration work was not legally relevant in cases such as that before it. ...

On that basis it strikes me that the intention of the subject provision as written might well be to exclude workers working abroad unless a very specific connection to Canada is established ...

Semantics may play too significant a role in making this distinction, yet the distinction is real: questions aimed at getting a witness to confirm that certain facts are proof of certain allegations are out; questions arrived at getting the witness to divulge relevant facts in connection with an allegation are in. ...

The cable connection cost $51.25 per month according to the statement- Exhibit A-15- issued by Rogers Cable TV in January, 1999. ...

There were some connections between two families at Conne River and other Bands in Nova Scotia. ...

As well, if the broad meaning of the expression "place of business" were used in applying paragraph 8(1)(f) of the Act, commission salespersons could not meet the condition of being required to carry on the duties of their employment "away from the employer's place of business", if all the locations where salespersons travelled to sell the employer's products (locations where salespersons carried on activities relating to the employer's business) were "places of business" of the employer. [31]     The expression "place of business" is also found in paragraph 20(1)(ee) of the Act, which authorizes deduction of the connection costs of public utilities at the place of business. ...

In that connection, Louis Sheff obtained a valuation from Blondeau & compagnie, actuaires et conseillers, of the amounts payable to him as per the 1985 agreement and [TRANSLATION] "the present value" of all the amounts thus payable was estimated at $1,058,619 (Exhibit I-1, Tab 10). ...

Although he was cross-examined at some length on this point, he did not refer to any actual experience in connection with the marketing of condominiums. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...