Harvey v. The Queen, 94 DTC 1910 (TCC)

The capital cost to the taxpayer of a yacht, that he bought in Canada and then had transported to the British Virgin Islands in order to be chartered on his behalf, included costs of work necessary to put the boat into shape to carry on the charter business, transportation and delivery costs, and import duties.

Bowman TCJ. found that there was no basis for the Minister to prorate a capital cost allowance claim for a taxation year of the taxpayer on the basis that the taxpayer did not commence the business in question until the last month of the year. Bowman TCJ. stated (p. 1915) that he could:

"see nothing in the Act that requires a person who starts a new business to shorten his taxation year simply because the business was not in operation for the full year."