Symes v. Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40 -- summary under Evidence

By services, 28 November, 2015

Iacobucci J. noted (p. 6014) that in determining the purpose for which an expense was made it should not be supposed that:

"Courts will be guided only by a taxpayer's statement, ex post facto or otherwise, as to the subjective purpose of a particular expenditure. Courts will, instead, look for objective manifestations of purpose, and purpose is ultimately a question of fact to be decided with due regard for all of the circumstances."

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