The taxpayer was not entitled to claim a deduction under s. 20(1)(l) because the sale giving rise to the receivable had not been reported in his return for the year of disposition. The Court rejected a submission that the requirement in ss. 12(1)(b) and 20(1)(l) that the amount receivable have been "included in computing" income required only that the taxpayer have taken that amount into account in computing his net income and did not establish a requirement that the amounts be reported on a tax return. Strayer JA stated (at para. 9):
Such a condition would be almost meaningless if the words "included in computing" did not require the reporting of such income in a current or previous return. That is, the Minister must be able to track back to a particular source of income if a deduction for doubtful debts is to be accepted in respect of that source.