How have courts interpreted the principle of "the law of the law" in the context of Inland Revenue Com'rs?

Manitoba, Canada


The following excerpt is from Winnipeg (City) v. Sabourin, 1980 CanLII 2511 (MB QB):

Viscount Simon in the case of D'Avigdor-Goldsmid v. Inland Revenue Com'rs, [1953] A.C. 347 at p. 362, dealt with the principle in these terms: The liability of the subject under a taxing statute ought not to be arrived at by a course of subtle and sophistical argument and, even in the case of the most learned judicial pronouncement, it is well to recognize that on rare occasions bonus dormitat Homerus.

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