Iacobucci J.:

1 In a narrow sense, this appeal raises one issue: how is a taxpayer to treat a payment made to a prospective tenant for the purpose of inducing that tenant to lease space in the taxpayer's premises? More specifically, is the expenditure, commonly referred to as a tenant inducement payment (“TIP”), to be deducted from income entirely in the year in which it was made, or is it to be amortized over the term of the lease to which it relates?