3 May 1988 Income Tax Severed Letter 7-2685 - [Deductible Medical Expense]

REVENUE CANADA, TAXATION MEMORANDUM

DATE : MAY 3 1988

TO: St. John's District Office Enquiries and Office Examination Section

ATTENTION: M. Holloway

FROM: 7-2685
        J.A. Szeszycki
        (613) 957-2130

RE: Medical Expenses

This is in response to your memorandum of March 21, 1988 requesting our opinion on whether necessary travel costs associated with bringing an individual to a location at which a donation of blood platelets can be made would be considered a deductible medical expense where those costs are borne by the recipient taxpayer.

We have reviewed the particular circumstances of this case and a similar case which has recently been brought to our attention and have taken the position that the interpretation of subparagraph 110(1)(c)(xiv) can be broadened sufficiently to include, as laboratory procedures or services, those costs necessary to bring the donor to the location where the donation is to be made, on the presumption that the nature of the donation is such that the presence of the donor is required at that location.

for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch