The facts of this case were that the taxpayer (and three others in partnership) entered a complex scheme, which involved the partnership, and annuity and loan arrangements. The scheme was financed through a series of "round robin" cheques and promised substantial deductions in the first five years of the 15-year plan. A number of documents were exchanged but no cash payments were made. This was calculated to return neutral cash flows with high tax deductions …showed first 75 words of 648 total…

…showed last 75 words of 648 total…anticipated in Phillip's case, a disparity between outlay and income may trigger a more rigorous examination of a contract or arrangement. As was suggested in Ure's case, the absence of a commercial quid pro quo will raise questions about the purpose of the expenditure. Where there is a dual purpose, or a purpose other than income production, expenditure is to be apportioned and there will be circumstances where purpose may mean subjective purpose or motive.