The taxpayer filed an election under s. 110.6(19) in respect of a seven-unit rental building on the basis that its adjusted cost base was $131,250 and fair market value was $262,500, but later sought to establish that the adjusted cost base was higher. Such adjusted cost base affected the computation of capital cost allowance claims for the taxpayer's 2007 and 2008 taxation years.
Masse DJ found (at para. 22) "that the Minister was correct in taking the ACB indicated by the appellant in her T664 election as a starting point to calculate the capital cost allowance for 2007 and 2008."