In McLeod v. M.N.R. (64 DTC 218), the taxpayer decided to convert the mortgage-free house in which he and his family were residing into a duplex and to move to a new smaller home, his intention being to obtain investment income and build up an estate. To finance the purchase price of $18,000 for the new house, the taxpayer arranged for a $9,000 mortgage on the old house and a $7,000 mortgage on his new home, and used $2,000 of his own funds. Interest on the said mortgages was disallowed. The taxpayer appealed to the Tax Appeal Board, which dismissed the appeal on the basis that the borrowed money was not used for the purpose of earning income from a business or property.