Expenditure in connection with fitness training was wholly and exclusively incurred for the purpose of a saturation diver’s trade and was therefore a deductible expense for tax purposes.
Summary
Expenditure in connection with fitness training was wholly and exclusively incurred for the purpose of a saturation diver’s trade and was therefore a deductible expense for tax purposes.
Background
The appellant was an experienced saturation diver in his late 40s (saturation diving is a diving technique that allows deep sea divers to reduce the risk of decompression by remaining in a pressurised environment (in a diving support vessel) for a period that can last for days or weeks.
The appellant contracted with a company to dive offshore in the Congo and North Sea. His 
