When asked how CRA's position - that a debt must be uncollectible in its entirety before it could qualify as a bad debt under s. 50(1) - could be reconciled with CRA's position that a partly bad debt could be deducted under s. 20(1)(p)(i), CRA first referred to the Hogan decision, and then stated (TaxInterpretations translation):
[T]he concept of debts in subparagraph 20(1)(p)(i) can refer to each account receivable of the taxpayer. Thus, following a diligent examination of the facts, certain of the amounts due by a customer can become uncollectible and these represent the portion of the debt which has become uncollectible.
On the other hand:
A debt can be eligible for the election under subsection 50(1) if it is uncollectible in its entirety at the end of a taxation year.