March 4, 1991
Audit Programs Directorate Rulings Directorate
Audit Applications Division R.B. Day
(613) 957-2136
Attention: W. Szyc910168
Application of 230(4) - Retention of Ticket Stubs
Further to our telephone conversation of February 25, 1991, we are forwarding the January 9, 1991, letter from 24(1) your consideration and reply.
A copy of our interim reply is also enclosed.
We examined our research file regarding this subsection and found that we have not been asked to consider the application of this provision relative to specific expense vouchers, such as ticket stubs.
Our Comments
It is our opinion that, whether or not ticket stubs should be retained in order to "verify the information contained ..." in this subsection, would depend on the over-all adequacy of the taxpayer's records relative to the specifics of the particular business enterprise. In other words it would be a judgement call as to whether retention of such records would be required in order to fulfil the compliance requirements of subsection 230(4).
19(1)
B.W. Dath Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
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