Occupancy Costs

"On August 31, 1978, the appellant sold his Forest Hill home for $86,500 and immediately loaned the proceeds, interest free, to his company to assist in financing construction of the new home. The company also obtained an $80,000 mortgage loan from Canada Trust for the same purpose. After the house was completed, the appellant and his family moved into it, and beginning on February 1, 1979, the appellant paid his company monthly rent of $1,100, including $300 for utilities. The Minister considered the rent paid during 1979 too low to represent the real value of the benefit or advantage conferred by the company on the appellant and his wife. The Minister estimated the value of that benefit for the year at $37,251, allocated one half to each spouse, and, after recognizing that the appellant had paid $12,100 for rent and expenses, determined that $6,526 was to be added to the appellant's income."