A taxpayer who used a second-mortgage loan on the individual’s residence to make interest and dividend-generating investments, was required by the lender to provide a certificate of location and an appraisal. After referring to Yonge-Eglinton and before finding that the resulting costs would be deductible under s. 20(1)(e)(ii), the Directorate stated:
[A]n expense is incurred in the course of a borrowing if it is in connection with, results from or arises from the manner of carrying out or the things that must be done to make the borrowing.