CRA addressed the deductibility under s. 60(o)(i) or 9 of the fees or expenses of professionals - incurred in dealing with questioning, demands for information, requested relief or denials by the taxing authority in a federal or provincial income tax context, deductible, as follows:
[S]ubparagraph 60(o)(i) applies to fees or professional fees incurred as part of an audit from the time that the taxpayer was informed that the taxpayer was subject to an audit or new examination respecting the taxpayer’s tax return.
[P]rofessional fees or expenses incurred to make a claim for interest and penalty relief [are] not deductible under section 9 or subparagraph 60(o)(i).
[T]he amount of the professional fees or expenses incurred to mount a challenge before the Administrative Tribunal of Québec following a decision rendered by Retraite Québec concerning the tax credit granting an allowance to families can generally be deductible under 60(o)(i).