The
Chairman:—The
taxpayer,
a
resident
of
Willowdale,
Ontario,
is
employed
as
a
securities
salesman
by
Thomson
&
McKinnon
Inc,
Brokers.
In
addition
he
purports
to
perform
bookkeeping
and
accounting
services
at
his
residence.
As
regards
both
occupations
he
appeals
against
the
disallowance
by
the
respondent
of
certain
expenses
incurred
during
1968.
In
connection
with
the
expenses
claimed
relative
to
his
self-employment,
such
of
these
as
were
disallowed
by
the
Minister
were,
I
consider,
properly
so
treated
and
I
see
no
occasion
to
interfere
with
what
has
been
done.
No
further
comments
seem
to
be
necessary.
The
real
bone
of
contention
herein
involves
the
sum
of
$440.00
claimed
to
be
deductible
as
a
travelling
allowance.
The
facts
are
that
the
appellant
was
sent
to
New
York
by
the
employing
company
for
the
purpose
of
attending
a
training
course
there
that
was
calculated
to
improve
his
efficiency
as
a
security
salesman.
The
appellant
was
at
New
York
from
April
28,
1968
to
August
30,
1968.
During
that
period
he
was
paid
his
regular
salary
by
the
company
and
also
given
the
sum
of
$440.00,
or
$110.00
per
month,
toward
his
expenses
in
that
city.
These
were
added
to
his
declared
income
by
the
respondent
when
assessing
the
appellant
for
1968.
The
appellant
complains
of
this
action
on
the
respondent’s
part
and
submits
that
all
expenses
incurred
by
him,
other
than
travelling
expenses,
should
be
allowed
as
a
deduction.
This
contention
is
based
on
the
wrong
premise.
As
has
been
held
by
the
Board
in
a
number
of
similar
cases
over
the
years,
expenses
incurred
in
taking
courses
of
instruction
are
not
expenses
incurred
to
earn
income.
The
course
may
prove
useful
to
the
appellant
in
future
years
and
eventually
increase
his
earning
power,
but
it
certainly
cannot
be
taken
into
account
in
the
year
in
which
the
course
is
taken.
Income
tax
assessing
generally
involves
one
year
at
a
time
and
it
is
the
expenses
incurred
in
that
year
to
earn
income
that
are
properly
deductible
and
no
others.
The
taking
of
a
course,
moreover,
may
probably
be
said
to
create
a
capital
asset
rather
than
immediate
income-earning
capacity.
What
the
appellant
learns
from
taking
a
course
becomes
peculiarly
his
property,
or
an
addition
to
knowledge
which
he
alone
acquires,
and
in
that
sense
it
virtually
forms
a
capital
asset.
Expenses
borne
in
relation
to
this
course,
be
these
travelling
or
other
expenses,
were
essentially
“personal
or
living
expenses”
and
therefore
not
deductible
in
the
light
of
paragraph
12(1
)(h)
of
the
Income
Tax
Act.
The
appellant’s
quarrel,
if
he
has
grounds
for
one,
should
be
with
his
employer
for
not
granting
a
sufficient
allowance
for
his
expenses
in
New
York;
certainly
no
relief
is
forthcoming
under
the
said
Act.
Having
regard
to
the
foregoing,
the
appeal
has
to
be
dismissed,
as
was
observed
at
the
conclusion
of
the
hearing
at
Toronto.
Appeal
dismissed.
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