http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/66639/index.do 
http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/66640/index.do 
Braithwaite v. The Queen[1] (January 28, 2014) is actually two appeals, one income tax and one GST, concerning income tax deductions and Input Tax Credits available to a real estate agent. The taxpayer claimed substantial losses in his 2006 taxation year which resulted in a net business loss:
[4] In computing his income for the 2006 taxation year, the appellant reported commissions received in the amount of $41,137 and claimed business expenses of $54,753.55 for a net business loss of $13,616.55.
Of this total the Minister disallowed expenses totalling $20,463:
Interest
|
$3487 |
| Motor Vehicle |
$5151 |
| Travel |
$6026 |
Others (office, telephone and others)
|
$4779 |
The Tax Court denied most of the disputed deductions either on the basis that they were personal expenses or inadequately documented. The court did allow the disputed claim for $1,020 in advertising expense and a corresponding Input Tax Credit on this amount in the companion GST appeal:[2]
Advertising Expenses
[29] The documentary evidence filed in Court by the appellant concerns a 36‑month renewal advertising agreement in the Real Estate Today editorial published by Black Press. A one-time cost of $1,000 (plus tax) was charged to the appellant and was included in the carryover of 2004. The amount of $1,070.38[3] was paid in July 2006, in addition to the $3,659.36 payment made in 2006. Contrarily to the CRA’s determination, the payment of $1,070.38 was not included in the appellant’s claim of $2,890 for 2004 because the appellant was using the cash method for claiming expenses during those years. These expenses should be deductible in computing the appellant’s business income.
[1] 2014 TCC 28 & 29.
[2] [7] Considering my reasons and decision in the appellant’s income tax appeal (2012-911(IT)I), the appeal is allowed and the reassessment is referred back to the Minister for reconsideration and reassessment on the basis that the appellant is entitled to an additional ITC in the amount of $219.32 [on advertising expenses] for the period from January 1 to December 31, 2006, with adjustments to interest and penalties.
[3] The reason for the differing amounts of advertising expense ($1,020.00 and $1,070.38) is unclear from the reasons.