In finding that the taxpayer was entitled to a tax credit in respect of tuition fees paid to a university in England that provided online courses (Open University in a program leading to a Masters of Science in Manufacturing, Management and Technology), Woods J. stated (at p. 2687):
"The expression 'full-time attendance' is ambiguous and in my view it should be interpreted liberally to include programs that require the 'attention' of the student on a full-time basis, such as the online program taken by Ms Valente."