9 January 2001 Internal T.I. 2000-0058047 F - FRAIS JURIDIQUES -- summary under Legal and other Professional Fees

A director who was assessed under ETA s. 323 and the Quebec equivalent for unpaid GST/QST of the inactive corporation was not able to deduct the legal fees incurred by him in negotiations with the tax authorities and objecting given that ss. 8(1)(b), 60(o) or 60(o.1) were inapplicable and such expenses were not regarded as having been incurred by him to earn income from a business or property.