Trzop v. Canada, 2002 DTC 6728, 2001 FCA 380 -- summary under Subsection 164(4.1)

The taxpayer had acquired debt with a nominal adjusted cost base to it and successfully argued before the Supreme Court of Canada that subsequent payments to him of interest that had accrued before he had acquired the debt were excluded from his income pursuant to s. 20(14). The realization of a taxable capital gain pursuant to s. 40(3) was a logical and inevitable consequence of the decision of the Supreme Court that s. 20(14) applied. Accordingly, this consequence was required to be taken into account by the Minister in reassessing the taxpayer following that decision.