In finding that a settlement agreement had been reached on terms as construed by the taxpayer rather than the Minister, Campbell J stated (at para. 47):
A contract will be found to validly exist where the party accepting the offer could reasonably be expected to know the other party's meaning even where it is not specifically communicated. ... [T]he extrinsic factual matrix supports the Appellant's interpretation of the settlement agreement while in no way supporting the Respondent's interpretation. Consequently, the Appellant's understanding and interpretation, which is reasonably supported by the factual matrix and law, ought to have been known to and considered by the Respondent when accepting the Appellant's settlement offer.