Taylor,
J.T.C.C.:—This
is
an
appeal
under
the
informal
procedure,
heard
in
Toronto,
Ontario,
on
January
26,
1994,
against
an
income
tax
assessment
for
the
year
1990,
in
which
the
Minister
of
National
Revenue
disallowed
an
amount
of
$5,482.12
of
the
total
of
$11,694.12
expenses
deducted
by
the
appellant
from
her
employment
income
of
$49,400.
It
is
clear
from
the
evidence
that
the
appellant
was
under
a
"contract
of
employment”
and
not
operating
as
an
“independent
contractor".
While
I
have
no
doubt
that
the
appellant
expended
all
or
most
of
the
claimed
expenses
on
matters
which
she
considered
related
to
her
employment,
and
that
such
expenses
were
beneficial
to
her
employer,
the
Income
Tax
Act,
R.S.C.
1952,
c.
148
(am.
S.C.
1970-71-72,
c.
63)
(the
"Act")
does
not
permit
the
deduction
of
the
disallowed
amounts.
It
is
even
difficult,
in
the
circumstances
of
this
case
to
substantiate
the
expense
of
$6,212
which
was
allowed
by
the
Minister—but
that
is
for
the
Minister
to
decide.
Some
other
contractual
arrangements
for
income
and
related
expenses
might
have
been
arranged
between
the
employer
and
this
employee
which
would
have
resulted
in
a
different
result—but
I
can
only
deal
with
the
information
before
me,
and
it
does
not
support
her
claim.
The
appeal
is
dismissed.
Appeal
dismissed.
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