Eugene Kalthoff v. Her Majesty the Queen, [1991] 2 CTC 359, 92 DTC 6001

Heald, J.A. (Hugessen and MacGuigan, JJ.A concurring):—We have not been persuaded that the learned trial judge committed any reviewable error herein. In our view, the facts at bar simply do not establish a borrowing by the taxpayer so as to permit any deductions under section 20 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63).

The appeal will therefore be dismissed with costs.

Appeal dismissed.