Does the matching principle apply to TIPs?

15 Relying on the case of Cummings v. The Queen, 81 D.T.C. 5207, and the interpretation thereof in the trial judgment in Toronto College Park Ltd. v. Canada (a companion case to the instant appeal), Brulé J. found that in certain cases, TIPs may be classified as running expenses, which in some cases may be deducted in the year of the expense. Further, he found that the matching principle had been held not to apply to such expenses. To Brulé J., these cases were determinative, such that the TIPs here at issue qualified as running expenses.