After noting that, in exceptional circumstances, interest on borrowed money may be deductible even if the direct use of the borrowed funds is not an eligible use, Malone J.A. stated (at p. 6807):
"We are satisfied, as found by the Tax Court Judge, that events subsequent to the loan arrangement ... provide some evidence of Helicopters' purpose and intention in obtaining the loan. An analysis which excludes consideration of events and evidence arising after the funds had been put to their original use, would severely limit the exceptional circumstances inquiry. In our view, events arising after the fact can have probative value in an exceptional circumstances inquiry."