The fact that tax is a statutory creature (see ¶150) and the ability of the courts only to hear appeals based upon an error of law (see ¶180) means that they will, in most cases, find it necessary to construe the words of the statute to ascertain their applicability to the facts in question. All statutes are subject to certain rules of interpretation, but whereas with non-fiscal legislation the courts may resolve any absurdity by looking at the spirit and intendment of the Act, they are more reluctant to do so with fiscal legislation. In 1970, Lord Donovan outlined the rules governing the interpretation of tax legislation:

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