An interpretation was avoided which would have rendered redundant the exclusion from income under s. 56(1)(n), for the first $500 of prize money, by including that same amount in income under s. 6(1)(a) (p. 5416). In rejecting the Crown’s submission that the prize was taxable under s. 5 or 6, Dickson J stated (at p. 446, SCR):
Section 56(1)(n) makes it clear that a prize for achievement is income from a source under s. 3 just as income from an office or employment is income from a source under s. 3. If a prize under $500 would still be taxable under ss. 5 and 6, it would have to follow on the Crown's argument that a prize under $500 would equally be taxable under s. 3. That cannot be right. That would mean that a prize over $500 would be taxable under s. 56(1)(n) and a prize up to $500 would be taxable under s. 3. The $500 exclusion in s. 56(1)(n) would never have any effect.