lacobucci, J.:—These appeals concern the interpretation of subsection 20(14) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"). This section permits a transferee of a debt instrument to deduct from the calculation of his or her taxable income the interest accruing on the instrument prior to the date of transfer.