What is the test for deducting from income tax under the Income Tax Reform Act?

Canada (Federal), Canada

The following excerpt is from Labow v. Canada, 2011 FCA 305 (CanLII):

Paragraph 18(1)(a) of the Act provides that no outlay or expense may be deducted from the income of a taxpayer unless it was made or incurred for the purpose of gaining or producing income from a business or property. The purpose of an expenditure is a question of fact to be decided with due regard to all of the circumstances: Symes v. Canada, 1993 CanLII 55 (SCC), [1993] 4 S.C.R. 695 at page 736.

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