The taxpayer, a Revenue Canada appraiser to the Appraisal Institute of Canada, who paid fees to the Appraisal Institute of Canada, which was not given any special status by statute although three provincial statutes or the regulations thereunder required certain appraisals to be performed by a member of that or a similar institute. In finding that the taxpayer was entitled to deduct the fees, Rothstein J.A. stated (at p. 5189):