Although on the advice of her accountants, the taxpayer, who previously had carried on her pharmacy practice as a sole proprietor, caused a company to be incorporated and began routing all payments and receipts through a company bank account, she otherwise continued to carry on her practice as before. Furthermore, s. 27 of the Pharmacy Act (Quebec) provided that only an individual pharmacist could buy and sell medications. In finding that all the amounts received from the pharmacy practice were includable in the taxpayer's income, Tardif TCJ stated (at p. 3193):
"The creation of a separate legal entity or the creation of a corporation is far more than an accounting process that may have tax advantages. It must be coherent and above all consistent with its real operation."