Sun Life Assurance Co. of Canada v. R., 97 DTC 422, [1997] 3 C.T.C. 2593 (TCC) -- text
Bowman T.C.J.:
1 These appeals are from loss determinations made under the Income Tax Act for the 1981, 1982 and 1983 taxation years. The narrow question is whether the cost of “acquiring” zoning from a landowner across the street that would permit a greater density is a cost of land or building or, if neither, whether it is an eligible capital expenditure.