The taxpayer, who did not like to golf, was required by his employer to belong to a golf club. He used the facilities only very occasionally. The amount of the annual membership dues paid by his employer was not includable in his income. Bowman C.J. stated (at para. 20) that the principle to be extracted from the Canadian, U.K. and U.S. jurisprudence "is that a 'benefit' is not included in an employee's income if it is primarily for the need or convenience of the employer" and that "this is so even where it represents a material acquisition or something of value". He went on to note (at para. 24) that here "membership in the golf club was clearly primarily for the benefit of the employer" (and, in any event "the benefit, if any, to the appellant of the membership in the golf club was minimal at most".
Bowman C.J. also noted (at para. 8) that "the meaning of 'enjoy' or 'jouir de' in section 6 has the meaning of 'have the use or benefit of' or 'avoir, bénéficier (de) posséder'."