Before concurring with Martland and Spence JJ. that legal expenses incurred by the taxpayer in connection with challenging potential assessments against its income by the U.S. revenue authorities were deductible, Hall J. stated (at pp. 5286, 5292):
A company such as the appellant exists to make a profit. All its operations are directed to that end. The operations must be viewed as one whole and not segregated into revenue producing as distinct from revenue retaining functions, otherwise a condition of chaos would obtain ... To limit the expenditure, if it is to qualify as a deductible, to the income of the particular year in which it was made requires writing into s. 12(1)(a) of the Income Tax Act words which Parliament did not put there. ... No limitation as to time can be found in the section in question.