In finding that the taxpayers are entitled to a deduction under s. 20(14)(b) because they complied with the expressed conditions of the provision, Iacobucci J. stated (p. 6321):
Where the words of the section are not ambiguous, it is not for this Court to find that the appellants should be disentitled to a deduction because they do not deserve a 'windfall', as the respondent contends. In the absence of a situation of ambiguity, such that the Court must look to the results of a transaction to assist in ascertaining the intent of Parliament, a normative assessment of the consequences of the application of a given provision is within the ambit of the legislature, not the Courts.