What is the test for successfully challenging a Minister of National Revenue's decision that disallowed expenses?
Canada (Federal), Canada
The following excerpt is from Cirone v. The Queen, 2010 TCC 137 (CanLII):
The Appellant bears the onus of proving that the facts upon which the Minister based the reassessments are wrong: Johnston v. Minister of National Revenue[3]. Therefore, in order to succeed, the Appellant is required to show that she incurred the disallowed expenses, and that they were incurred to earn income from her employment.
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