Impenco Ltd. — Impenco Ltee v. Minister of National Revenue, [1988] 1 CTC 2339, 88 DTC 1242 -- text
Couture, C.J.T.C.:—The appellant appeals an assessment for its 1984 taxation year whereby the respondent disallowed as a deduction in computing its income an amount of $122,604 claimed as an outlay or expense incurred for the purpose of earning income within