One of my favourite tax quotes is the following, which was written by the judge in J.F. Newton Ltd. v. Riddell, 45 D.T.C. 5276, [1991] 2 C.T.C. 91, 50 B.L.R. 136, 1990 CanLII 933 (BC S.C.), who was forced to review the wording and application of subsection 55(2) of the Income Tax Act in the context of the trial of a professional negligence claim:
It surpasses my imagination that anyone considers language such as this to be capable of an intelligent understanding, or that such language is thought to be capable of application to the events of real life, such as the sale of a business.
