A finder's fee and a commitment fee paid by the taxpayer in respect of a loan were non-deductible because the loan was made to a corporation which he had incorporated rather than to him personally.
In finding that the taxpayer and other investors who made an investment in a building were a syndicate for purposes of s. 20(1)(e), Rothstein J.A. referred, with approval to the following definition appearing in Romano v. MNR, 66 DTC 490, and 500 (T.R.B.):
"Any group of persons who have agreed to pool their resources of money or of specific assets for some common purpose."
