Before going on to accept evidence that stock dividends that produced the result described in s. 15(1.1) were not declared with that purpose in mind, Rowe D.J. stated (at p. 464):
"In my view the addition of the words 'it may reasonably be considered' in subsection 15(1.1) does not detract from the validity of examining the definition of 'purpose' as it pertains to the intention, end, aim, object, plan, project or goal to be accomplished or achieved. The additional words make it clear that an objective standard is to be applied to the evidence offered up by a taxpayer and fanciful, outrageous or otherwise unreliable testimony on the issue of purpose does not have to be accepted at face value any more than any other portion of testimony or piece of evidence even though it is forcefully expressed in a manner consistent with a deeply-held belief. It is apparent the standard to be applied against the taxpayer is much more stringent than where the language of the legislation used the word 'desired' as in subsection 56(2) of the Act as considered by the Federal Court of Appeal in Jones v. The Queen, 96 DTC 6015 (also reported as Ascot Enterprises v. R, [1996] 1 CTC 384."