The taxpayers were police union representatives. Lamarre J. affirmed the Minister's position that reimbursement from the union for meals were a taxable allowance rather than an excluded expense reimbursement because the union paid a fixed amount for each meal, irrespective of actual cost (para. 33). He also stated (at para. 34):
[T]he meal allowances that were included in the appellants' income were paid in connection with the appellants' performance of their duties within the municipality of Saguenay. Even though that municipality results from a merger of three former cities, the meals eaten within it cannot, in my view, be considered to have been eaten away from the municipality where the employer's establishment was located, or away from the metropolitan area where it was located.