The taxpayer, a Revenue Canada appraiser to the Appraisal Institute of Canada, who paid fees to the Appraisal Institute of Canada, which was not given any special status by statute although three provincial statutes or the regulations thereunder required certain appraisals to be performed by a member of that or a similar institute. In finding that the taxpayer was entitled to deduct the fees, Rothstein J.A. stated (at p. 5189):
"The dictionary definition of 'recognized' is, in this context, 'to acknowledge the existence, validity, character or claims of' ... . Parliament intended to restrict the meaning of 'recognized' to include the requirement of being 'incorporated', 'created' or 'regulated' by statute, it was open to it to use words to that effect."