In response to a submission that mining machinery and equipment had not been purchased "for the purpose of earning income" because the profits initially generated by the mine would be eligible for a federal and provincial tax holiday, Wilson J. stated:
If [as established in case law cited by her] there is no need to demonstrate a causal connection between a particular expenditure and a particular income, and no need for the income to be generated in the same year in which the expenditure was made, then it would not seem to matter whether Mattabi suffered tax losses in 1971 or that it would have been exempt from tax had it made a profit. The only thing that matters is that the expenditures were a legitimate expense made in the ordinary course of business with the intention that the company could generate a taxable income some time in the future.