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TCC

Mullin v. The Queen, docket 97-2815-IT-G

The Appellant has submitted a claim to the Respondent on account of medical expenses with respect to her 1995 taxation year (for medical expenses in connection with the period January 1, 1995 to December 31, 1995) in the amount of $4,907.35. 3. ... The difference between the position of the Appellant and the position of the Respondent in connection with the medical expense claim relates solely to the item respecting "travel-use of personal vehicle": (a) The Appellant has made a medical expense claim of $1,361.25 in connection with this item ($0.30 per kilometre); (b) The Respondent has allowed only $604.67 in connection with this item ($0.16 per kilometre). 5. The amount per kilometre that the Respondent has suggested as being reasonable is $0.16 per kilometre, being the amount that the Respondent is prepared to allow in connection with "travel-use of personal vehicle". 6. ...
FCA

St-Georges v. Canada, 2006 FCA 207

Accordingly, there is a real and direct connection between the expense claimed and the accounting firm ... In fact, in filing his income tax return for the year in issue, the appellant added US$100,000 he received for services rendered in connection with the legal proceeding to the amount he disbursed for the litigation and claimed the difference as a net loss resulting from this case. ...   [18]            Finally, for the reasons mentioned at paragraphs 30 to 33 of his reasons, I am of the opinion that the judge of the Tax Court was entitled to distinguish the appellant’s activities in connection with the sale of his client’s business from those in connection with the payment of a dividend ...
TCC

Mullin v. R., [1999] 2 CTC 2750, 99 DTC 748

The Appellant has submitted a claim to the Respondent on account of medical expenses with respect to her 1995 taxation year (for medical expenses in connection with the period January 1, 1995 to December 31, 1995) in the amount of $4,907.35. 3. ... The difference between the position of the Appellant and the position of the Respondent in connection with the medical expense claim relates solely to the item respecting “travel-use of personal vehicle”: (a) The Appellant has made a medical expense claim of $1,361.25 in connection with this item ($0.30 per kilometre); (b) The Respondent has allowed only $604.67 in connection with this item ($0.16 per kilometre). 5. The amount per kilometre that the Respondent has suggested as being reasonable is $0.16 per kilometre, being the amount that the Respondent is prepared to allow in connection with “travel-use of personal vehicle”. 6. ...
FCTD

The Queen v. Eggert, 85 DTC 5522, [1985] 2 CTC 343 (FCTD)

Counsel for this taxpayer then posited that because the jointly filed transcript (p 3) records that the taxpayer in his employment is “responsible for... the purchasing agent who purchases materials” he is by necessary implication, if not directly, contemplated by the expression “... employed in connection with the selling of property or negotiating of contracts for his employer’. ... He concentrated on the expression “... received by an employee from his employer in respect of a period when he was employed in connection with... ... The subparagraph might possibly bear such an interpretation if it provided, “... in respect of a taxation year during which he was employed for some period in connection with...”. ...
FCTD

Her Majesty the Queen v. Jack !. Salter, [1985] 2 CTC 338, 85 DTC 5525

It sufficiently establishes that, to that extent, he was employed in connection with negotiating of contracts for the County of Wellington. ... He concentrated on the expression,“... received by an employee from his employer in respect of a period when he was employed in connection with...” in subparagraph 6(1)(b)(v) of the Act. ... The subparagraph might possibly bear such an interpretation if it provided, “... in respect of a taxation year during which he was employed for some period in connection with.. ...
TCC

Placer Dome Inc. v. The Queen, 93 DTC 235, [1993] 1 CTC 2411 (TCC)

There were three important connections made between the Perry shaft and the Springer shafts: (a) The connection at the 975 foot level. ... (b) The connection at the 2,000 foot level. This connection served a number of important purposes. ... (c) The connection at the 275 foot level. As above stated, the main purpose of this connection was to provide backfill necessary in the Perry workings from the Springer workings. ...
FCTD

Bouchard v. Mitsubishi Motor Sales of Canada Inc., 2010 FC 56

The connection between the forum and the plaintiff’s claim 2. A connection between the forum and the defendant 3. ...   [43] Regardless, jurisprudence on the real and substantial connection test states that a connection between the defendant and the forum is an important factor, but not a necessary factor. ... A substantial connection with the subject matter of the action will satisfy the real and substantial connection test even in the absence of such a connection with the defendant to the action. ...
FCA

Canada v. Akiwenzie, 2004 DTC 6007, 2003 FCA 469

Is his exemption precluded because his connection is to more than one reserve? ... He has no less of a connection with a reserve simply because he had contact with 480 reserves. The connection must be established with each and every reserve, but need not be limited to just one. ...
T Rev B decision

D R Milne & Company Limited v. Minister of National Revenue, [1979] CTC 2294, 79 DTC 334

The benefit of the connection with insurance customers which had been built by Black over the years was intended and required to be transferred to the appellant so far as was possible. ... It is the benefit and advantage of the good name, reputation, and connection of a business. ... It is the formation of that connection which has made the value of the thing that the late firm sold, and they really had nothing else to sell in the shape of goodwill. ...
TCC

Wiley v. The Queen, 2005 TCC 659 (Informal Procedure)

They claimed 100% of their motorhome costs in connection with their business ... I presume the legislators did not mean that there is some expense in connection with not maintaining property, but intended that personal or living expenses are not expenses of property maintained in connection with a business. ... The Respondent has also acknowledged the motorhome was used in connection with that business, but only to the extent of 5%. ...

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