A fee which was found, on the evidence, to have been paid by the taxpayer to a consultant for investigating possible sites for a relocated manufacturing facility of the taxpayer was deductible under s. 20(1)(dd) notwithstanding that a related company actually acquired the site, constructed the building and leased the premises to the taxpayer. Hershfield J. stated (at para. 31):
"It is clear that what triggers the subject deduction is the cost of investigating the suitability of a site for the planned use of a hypothetical building that may never be built. If it matters not whether a building is ever built, how can it be said that the operation of a section depends on who builds it?"