| 921121 | |
| J.D. Brooks | |
| 957-2103 |
Apr 14/92 D R A F T
PRAIRIE PROVINCES TAX CONFERENCE
MAY 19 & 20, 1992
QUESTION 6
Does Revenue Canada consider that legal and accounting expenses incurred in responding to a proposal letter from Revenue Canada, prior to an assessment, are deductible pursuant to paragraph 60(o)?
RESPONSE
As stated in paragraph 6 of IT99R4, it is the Department's practice to allow a taxpayer to deduct amounts expended in connection with legal and accounting fees incurred for advice and assistance in making representations after having been informed that the taxpayer's income or tax for a taxation year is to be revised, whether or not a formal notice of objection or appeal is subsequently filed.