The appellant, a financial advisor, borrowed $100,000 to purchase a departing colleague's client list and sought to deduct the purchase price and the interest on the borrowed funds from his employment income.
The Minister of National Revenue denied the deductions.
The Supreme Court of Canada held that both the purchase price and the interest payments were payments 'on account of capital' and were therefore precluded from deduction under section 8(1)(f)(v) of the Income Tax Act.
The appeal was dismissed.
