The taxpayer, an insurance salesman, purchased a life insurance policy on himself and several family members, seeking to earn from the sale a commission in excess of the premiums he expected to pay on the policy before cancelling.
After finding that the commissions were business income, Hogan J. went on to find that the premiums paid by the taxpayer were not deductible in the computation of such business income by virtue of s. 18(1)(h). The definition of "personal or living expenses" in s. 248(1) includes insurance premiums on policies whose proceeds are payable to the benefit of the taxpayer or a related person.