The taxpayer unsuccessfully argued that Reg. 1102(1)(e)(iv) referred "to decorative objects and not objects that are used, as is the case with the musical instruments in question" (para. 25). It submitted that the noscitur a sociis principle applied, so that "any other antique object" must refer to objects sharing qualities with "antique furniture." Jorré J noted the statement of Pierre‑André Côté in The Interpretation of Legislation in Canada, 4th ed., Éditions Thémis, 2011 at para. 1179 that:
Although a good servant, the noscitur a sociis principle may prove to be a poor master. It can be misleading and should be handled with care.
He then stated (at para. 33):
Here, the Regulations do not mention "other similar object" or "decorative object". The context of the provision does not suggest a limitation other than objects that are more than 100 years old.