The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to pay for "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. Webb J. found that as it was not reasonable in the circumstances for the taxpayer to have believed that the container was real, the amounts expended by him also were not reasonable, and their deduction was denied in full by s. 67.
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