Commissioner of Inland Revenue v Brierley - [1990] 3 NZLR 303

Income tax — Deductions — Interest — Taxpayer borrowed money to buy shares in a company which paid both taxable dividends and non-taxable capital dividends — Taxpayer claimed the interest paid on his borrowings as deductions, but Commissioner apportioned the deductions on ratio of taxable to non-taxable dividends — Whether non-taxable dividends were exempt income — Whether Commissioner was correct in making apportionment — Whether interest was deductible — Income Tax Act 1976, ss 4, 104 and 106.