The taxpayers were police union representatives. They were allowed to perform their duties outside the hours the hours of work with their employer. Lamarre J. stated (at para. 29):
In such a case, the Expense Policy provided that the members of the Police Union's executive were entitled to a $50 allowance for each instance of participation in a union activity, up to the maximum total contemplated in the said Expense Policy. In my opinion, this constitutes fixed or ascertainable remuneration.