The Chairman:—The taxpayer, a resident of Willowdale, Ontario, is employed as a securities salesman by Thomson & McKinnon Inc, Brokers. In addition he purports to perform bookkeeping and accounting services at his residence. As regards both occupations he appeals against the disallowance by the respondent of certain expenses incurred during 1968. In connection with the expenses claimed relative to his self-employment, such of these as were disallowed by the Minister were, I consider, properly so treated and I see no occasion to interfere with what has been done. No further comments seem to be necessary.
The real bone of contention herein involves the sum of $440.00 claimed to be deductible as a travelling allowance. The facts are that the appellant was sent to New York by the employing company for the purpose of attending a training course there that was calculated to improve his efficiency as a security salesman. The appellant was at New York from April 28, 1968 to August 30, 1968. During that period he was paid his regular salary by the company and also given the sum of $440.00, or $110.00 per month, toward his expenses in that city. These were added to his declared income by the respondent when assessing the appellant for 1968.
The appellant complains of this action on the respondent’s part and submits that all expenses incurred by him, other than travelling expenses, should be allowed as a deduction. This contention is based on the wrong premise. As has been held by the Board in a number of similar cases over the years, expenses incurred in taking courses of instruction are not expenses incurred to earn income. The course may prove useful to the appellant in future years and eventually increase his earning power, but it certainly cannot be taken into account in the year in which the course is taken. Income tax assessing generally involves one year at a time and it is the expenses incurred in that year to earn income that are properly deductible and no others. The taking of a course, moreover, may probably be said to create a capital asset rather than immediate income-earning capacity. What the appellant learns from taking a course becomes peculiarly his property, or an addition to knowledge which he alone acquires, and in that sense it virtually forms a capital asset. Expenses borne in relation to this course, be these travelling or other expenses, were essentially “personal or living expenses” and therefore not deductible in the light of paragraph 12(1 )(h) of the Income Tax Act.
The appellant’s quarrel, if he has grounds for one, should be with his employer for not granting a sufficient allowance for his expenses in New York; certainly no relief is forthcoming under the said Act.
Having regard to the foregoing, the appeal has to be dismissed, as was observed at the conclusion of the hearing at Toronto.
Appeal dismissed.