D.S. Delorey (613) 957-2129
May 30, 1986
Dear Sirs:
This is in reply to your letter of April 1 concerning the deductibility of the cost of client and insurance policy information and the legal fees incurred to obtain the information.
The decision in the Partykan case ( 80 DTC 1475), to which you refer in your letter, was based on a finding of fact. Thus, it may be relied upon only in cases where the facts are identical. Otherwise, the Department's position with respect to the cost of acquiring the type of information acquired by Mr. Partykan is set out in Interpretation Bulletin IT-187 , a copy of which is enclosed for your perusal, and with respect to legal fees is set out in Interpretation Bulletin IT-99R3 , a copy of which is also enclosed for your perusal.
We trust these comments will be of assistance.
Yours truly,
ORIGINAL SIGNED BY
Wm. R. McColm
for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch