Ease of Administration

After noting that the minority proposed that the distinction between deductible and non-deductible fines be determined on a case-by-case basis, Iacobucci J. stated (at para. 68) that in his view "such an approach would be quite onerous for the taxpayer who would be forced to undertake the difficult task of determining the object or purpose of the statute under which the payment was demanded whenever he or she filled out a tax return".