The taxpayer, an independently practising lawyer, paid his wife $45,000 in the year as remuneration for bookkeeping and office management services. The Minister disallowed the taxpayer's deduction of the remuneration on the basis that the sporadic manner of its payment suggested an income-sharing arrangement rather than salary. In allowing the deductions, Hogan J. stated (at para 14):
The ITA does not require that a salary be paid on a regular basis.