The Queen v. Lalonde, 84 DTC 6159 (FCTD), aff'd 89 DTC 5286 (FCA)

Legal fees incurred by a doctor in order to dispute a decision not to build a comprehensive school in his immediate area were incurred for the purpose of increasing the revenues of his pharmaceutical business and medical practice, and thus were deductible. (It was accepted that he felt that a new school would increase the population, and thus the potential number of patients, in the area.)

Two doctors, who had never carried on a business of providing security or lending money, made interest-free advances to a non-profit corporation which had been established to construct and operate an old-age home. They also became sureties for bank loans. Since their intention in becoming so obligated was to foster an increase in the number of potential patients for their practice and thereby create an enduring benefit, the ensuing losses were on capital account.

Two doctors made interest-free advances to a non-profit corporation which had been established to construct and operate an old-age home. Since their purpose in loaning the money was to foster an increase in the number of potential patients in their immediate area, and thereby increase their professional income, the debt was acquired for the purpose of producing business income.