Canada v. Stapley, 2006 DTC 6075, 2006 FCA 36 -- summary under Resolving Ambiguity

Sexton J.A. found that although a purposive interpretation of s. 67.1(1) would have resulted in a conclusion that the taxpayer was not subject to the expense-deduction limitation in that provision, the plain meaning of the provision and the legislative scheme indicated that the limitation applied. Accordingly, the taxpayer's appeal failed.