In noting that a taxpayer's credible oral evidence does not necessarily need the support of source documents, Nadon JA stated (at para. 72):
The Associate Chief Justice appears to have elevated the judicial requirement that supporting documents may be required for a taxpayer to establish his or her claims and deductions to an authoritative principle that documents will always be required for a taxpayer to establish his or her case. There is, in my respectful view, no principle to the effect that oral evidence must necessarily be supported by source documents.