What is the test for applying the "rule of lenity" to reverse convictions under Section 33 of the Criminal Code?

Appellants again urge application of the rule of lenity to reverse their convictions, pointing to the "uncertainty" of their tax obligations. "The rule of lenity only applies, however, where there is a grievous ambiguity or uncertainty in the language and structure of the statute, such that even after a court has seized every thing from which aid can be derived, it is still left with an ambiguous statute. . . ." United States v. Carona, 660 F.3d 360, 369 (9th Cir. 2011), as amended (citation, alterations, and internal quotation marks omitted). "Because the meaning of language is inherently contextual, we have declined to deem a statute ambiguous for

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