Words and Phrases - "ordinary course"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

Heron Bay Investments Ltd. v. The Queen, 2009 DTC 1606, 2009 DTC 1288

Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense

The taxpayer incurred an expense of $89,799 for the rezoning of a parking lot so that the construction of a condominium building would be permitted. The condominium project later was cancelled. The taxpayer sought to deduct the expenditure on the basis that this was equivalent to having added the expenditure to the cost of its parking lot, viewed as land inventory, and then deducting this amount in light of a decline in the value of the property. Hogan, J. dismissed the taxpayer's appeal with respect to this issue because no evidence or submissions were provided by it, and noted that in light of the jurisprudence "it could be argued that the cost incurred for the rezoning should be added to the land" (para. 124).

Words and Phrases
ordinary course