After noting that in the case before him the Crown was challenging the deduction under s. 20(1)(f) of amounts paid as a result of foreign currency appreciation whereas CRA had allowed deductions under that provision based on appreciation of commodities in commodity-based loans, LeBel J. stated (at para. 59):
"However much they are to be deplored, inconsistent administrative practices are not the determinative factor in statutory interpretation. We must nevertheless return to the statute itself and to the scope of its application in respect of the specific transactions at issue in these appeals ... . If an interpretation is wrong, it does not make law."