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Although the Crown was successful, Wetston J. rejected a submission of the Crown that two businesses cannot be a combined chief source of income if there is no connection between those two revenue sources. ...

The Queen, 2004 DTC 2784, 2004 TCC 381 (Informal Procedure)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) After the taxpayer took an assignment (initially scheduled for two years) to work in Belize she maintained her home in Vancouver where her son and family resided, maintained her banking and financial interests in Canada, visited her connections in Vancouver approximately once per year, had no intention to reside on any permanent basis in Belize and considered Vancouver as a place where she could reconnect if need be. ...

Bowman C.J. stated (at p. 242) "residual friendships and employment connections do not create residency". ...

Noël J.A. stated (at p. 6010) that "it cannot be said that the taxation of the respondent's income would result in the erosion of his entitlement qua Indian on any or all of these reserves as there is no connection whatsoever between this income as such and these reserves as economic bases or physical location.... ...

Before partially granting a motion for the filing of a list of administrative interpretations in connection with an appeal by a judge of a reassessment disallowing his RRSP deduction, Lamarre Proulx TCJ. stated (p. 1319) that she did not: "see why, if there are administrative interpretations concerning contributions to a pension plan and to a registered retirement saving plan which have been sent or made available to the judges in a general manner, a list of both administrative interpretations should not be produced for the purposes of this appeal. ...

The Queen, 87 DTC 5391, [1987] 2 CTC 183 (FCTD)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Legal fees paid by the taxpayer for the successful defence of its president against fraud charges brought in connection with alleged activities in which the taxpayer had no direct involvement, were non-deductible. ...

In finding that this did not give rise to a taxable benefit under a section which referred to the "expense incurred in or in connection with" provision of in-house benefits, it was found that this section referred to the additional expenses attributable to each boy (such as food, stationery and laundry) rather than a proportion of all the running expenses of the school. ...

La Reine, 2006 DTC 2969, 2004 TCC 688-- summary under Damages Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Damages Damages paid by the taxpayer in respect of the payment of a dividend to him by a corporation of which he was a director were not amounts incurred by him in connection with any business given that his directorship was not an office (as he was not entitled to any remuneration for acting in that capacity), and amounts earned for accounting services rendered to the company were earned by a corporation owned by him rather than him directly. ...

Minister of National Revenue, 66 DTC 5116, [1966] CTC 150, [1966] S.C.R. 384-- summary under Scheme Summary Under Tax Topics- Statutory Interpretation- Scheme In connection with finding that land upon which the timber had been removed should be regarded as part of a timber limit, in order to avoid the deduction by the taxpayer of depreciation in excess of the net cost to it of the land, Cartwright J. stated (p. 5120): "The answer to the question what tax is payable in any given circumstances depends, of course, upon the words of the legislation imposing it. ...

., 83 DTC 5095, [1983] CTC 90 (FCTD)-- summary under Paragraph 239(1)(f) Summary Under Tax Topics- Income Tax Act- Section 239- Subsection 239(1)- Paragraph 239(1)(f) It was stated, in connection with a case where the accused had corroborated the V-day value of land with false documentation, that: "I do not conceive how any precise finding of value dependent on the opinion evidence of experts in land valuation could be arrived at beyond a reasonable doubt [:] R. v. ...