Question juridique clé
Whether a newly changed administrative practice on nursing-home health-cost deductions applies to an older 1997 tax assessment.
Solution extraite
Yes. Because the statutory provisions were unchanged, the new practice was a fresh interpretation of existing law and could be applied to the pending case.
Motifs extraits
The court held that the question was not a change of law but a new interpretation of the same provisions; the more taxpayer-friendly practice better matched the purpose of the health-cost deduction and federal harmonization.