In finding that “accumulation”, in the context of the highly detailed statutory provisions of the ITA, was to be given the meaning that would be understood in the industry, Sharlow JA stated (at para. 34):
The Crown argues that the word "accumulation" was intended to be read in the sense [in] which it would be understood in the industry. In my view, that is the correct approach to a word as general as "accumulation" when it is used in the context of highly detailed statutory provisions that are intended to be of use to a particular industry.