Canada v. Stapley, 2006 DTC 6075, 2006 FCA 36 -- summary under Subsection 67.1(1)

The taxpayer, who was a real estate agent, was only entitled to deduct one-half of the cost of gift certificates for food and beverages, and of tickets to various sporting events and concerts, purchased for clients. Although it would be contrary to a purposive interpretation of the provision to apply the denial because the taxpayer did not consume any food or enjoy any of the entertainment in issue, the plain meaning of the provision (there being nothing in it to limit its application to situations in which the taxpayer participated in the consumption of the food or beverages or in the enjoyment of the entertainment, and the phrase "in respect of" having a wide meaning) and the scheme of the provision (there being two exceptions in s. 67.1(2) that would be redundant if the provision only applied where the taxpayer had such personal consumption) indicated that the provision applied.