Lamarre J dismissed the taxpayer's arguments that he should be able to deduct interest on tax arrears as a business expense. Such deductions were prohibited by s. 18(1)(t).
In any event, the interest payments would not have been deductible under s. 20(1)(c). There was no borrower-lender relationship with the Crown as CRA did not agree to lend money to the taxpayer and the taxpayer instead owed tax under the Act, and there was no contractual agreement between the two parties (paras. 13-14).