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Therefore, to use the words of Justice Mackay in Graves (4.02(9)) at page 362 (D.T.C. 6300-6304): "The type of deductions contemplated under paragraph 18(1)(a) of the Income Tax Act do not include expenses arising simply by virtue of casual connection to a business activity.... they must also be reasonable expenses. ...

Keith McNair in Taxation of Farmers and Fishermen (Richard De Boo Publishers), this concept of the government right as calculated applies specifically for the benefit of farmers (chapter 3, p. 3-55) in connection with the milk quotas which existed before 1972. ...

The Court stated that: a) the taxpayer was equally motivated by both an investment purpose and a tax purpose; b) that the payment made by him was for a bona fide business purpose and not motivated solely for tax advantages; c) no reasonable inference could be drawn that the amount claimed was excessive, unreasonable, unnatural or abnormal; d) the evidence at the hearing fell short of establishing any connection or conspiracy between the various parties which would support a finding of artificiality, simulation or fiction. ...

. …, is it the Crown’s position that it is proceeding … with the tax-shelter allegation and argument in connection with Mr Chad’s 2011 tax year? ...

Subsection 28(1) reads as follows: 28. (1) For the purpose of computing the income of a taxpayer for a taxation year from a farming or fishing business, the income from the business for that year may, if the taxpayer so elects, be computed in accordance with a method (in this section referred to as the "cash method") whereby the income therefrom for that year shall be deemed to be an amount equal to the aggregate of (a) all amounts that (i) were received in the year, or are deemed by this Act to have been received in the year, in the course of carrying on the business, and (ii) were in payment of or on account of an amount that would, if the income from the business were not computed in accordance with the cash method, be included in computing income therefrom for that or any other year, and (b) such amount, if any, as may be specified by the taxpayer in respect of the business in his return of income under this Part for the year, not exceeding the fair market value at the end of the year of livestock (other than animals included in his basic herd within the meaning assigned by section 29) owned by him at that time in connection with the business minus the aggregate of (c) all amounts that (i) were paid in the year, or are deemed by this Act to have been paid in the year, in the course of carrying on the business, and (ii) were in payment of or on account of an amount that would, if the income from the business were not computed in accordance with the cash method, be deductible in computing income therefrom for that or any other year, and (d) the amount, if any, specified by the taxpayer in respect of the business in accordance with paragraph (b) in his return of income under this Part filed for the immediatley preceding taxation year; and minus any deductions for the year permitted by paragraphs 20(1)(a) and (b). ...

(c) To the joint account the Company shall charge as a debit: (i) all charges and expenses incurred by or for the benefit of the Company in the acquisition, exploration, development and operation of the oil and gas properties, and the processing of petroleum substances produced therefrom, including all plant costs; (ii) the reasonable and proper overhead costs of the Company attributable to the oil and gas properties which, in the case of oil and gas properties subject to a third party agreement, shall be the overhead costs provided for pursuant to such third party agreement and in all other cases shall be the reasonable and proper overhead charges as determined in the sole discretion of the Company; (iii) the costs incurred by or for the benefit of the Company for third party services engaged in connection with the exploration, development and operation of the oil and gas properties; (iv) the costs incurred by or for the benefit of the Company for acquiring, establishing and maintaining title to the oil and gas properties including rentals, legal costs and the cost of accounting or bookkeeping services attributable to the interest of the Company therein; (v) interest on the debit balance in the joint account from time to time at the same rate from time to time applicable to repayable on demand borrowings by the Company from its Bank. ...

Miller in reliance on subsection 231.1(1) of the ITA. [21] Subsection 231.1(1) reads as follows: 231.1 (1) An authorized person may, at all reasonable times, for any purpose related to the administration or enforcement of this Act, 231.1 (1) Une personne autorisée peut, à tout moment raisonnable, pour l’application et l’exécution de la présente loi, à la fois: (a) inspect, audit or examine the books and records of a taxpayer and any document of the taxpayer or of any other person that relates or may relate to the information that is or should be in the books or records of the taxpayer or to any amount payable by the taxpayer under this Act, and a) inspecter, vérifier ou examiner les livres et registres d’un contribuable ainsi que tous documents du contribuable ou d’une autre personne qui se rapportent ou peuvent se rapporter soit aux renseignements qui figurent dans les livres ou registres du contribuable ou qui devraient y figurer, soit à tout montant payable par le contribuable en vertu de la présente loi; (b) examine property in an inventory of a taxpayer and any property or process of, or matter relating to, the taxpayer or any other person, an examination of which may assist the authorized person in determining the accuracy of the inventory of the taxpayer or in ascertaining the information that is or should be in the books or records of the taxpayer or any amount payable by the taxpayer under this Act, b) examiner les biens à porter à l’inventaire d’un contribuable, ainsi que tout bien ou tout procédé du contribuable ou d’une autre personne ou toute matière concernant l’un ou l’autre dont l’examen peut aider la personne autorisée à établir l’exactitude de l’inventaire du contribuable ou à contrôler soit les renseignements qui figurent dans les livres ou registres du contribuable ou qui devraient y figurer, soit tout montant payable par le contribuable en vertu de la présente loi; and for those purposes the authorized person may à ces fins, la personne autorisée peut: (c) subject to subsection 231.1(2), enter into any premises or place where any business is carried on, any property is kept, anything is done in connection with any business or any books or records are or should be kept, and c) sous réserve du paragraphe (2), pénétrer dans un lieu où est exploitée une entreprise, est gardé un bien, est faite une chose en rapport avec une entreprise ou sont tenus ou devraient l’être des livres ou registres; (d) require the owner or manager of the property or business and any other person on the premises or place to give the authorized person all reasonable assistance and to answer all proper questions relating to the administration or enforcement of this Act and, for that purpose, require the owner or manager to attend at the premises or place with the authorized person d) requérir le propriétaire, ou la personne ayant la gestion, du bien ou de l’entreprise ainsi que toute autre personne présente sur les lieux de lui fournir toute l’aide raisonnable et de répondre à toutes les questions pertinentes à l’application et l’exécution de la présente loi et, à cette fin, requérir le propriétaire, ou la personne ayant la gestion, de l’accompagner sur les lieux. [22] As stated in the preamble to the subsection, a request made by the Minister pursuant to subsection 231.1(1) must relate to the administration or enforcement of the ITA, a requirement that is not in dispute between the parties. ...

In my view, the prothonotary was perfectly right in allowing those costs as they were obviously incurred, and properly so, in connection with the various examinations for discovery. ...

The only connection is whether that which was sought from Ford in the law suit, is a reflection of the payments made to Ford — and it appears to be an identical amount. ...

In view of these circumstances, we would appreciate if the Soil Conservation Officer would give approval to removal of all the top soil on the property and I would appreciate if you would advise in that connection at your earliest convenience. ...