David Dyer v. Minister of National Revenue, 91 DTC 630, [1991] 1 CTC 2505 (TCC) -- text
Mogan, T.C.J.:—In the fall of 1981, the appellant paid $42,750 to purchase the house located at 5 Gower Street in St. John’s, Newfoundland. He acquired only a leasehold interest. In the first eight months of 1982, the appellant paid approximately $33,000 to contractors and suppliers to renovate the house. When the work was completed, there were two self-contained apartments: one on the second and third floors and one on the ground floor and basement. The appellant occupied the lower apartment and, in August 1982, he rented the upper apartment.