In finding that fees paid to an accounting firm to file claims for investment tax credits did not qualify as "directly related" to the prosecution of scientific research and experimental development, Mogan D.J. stated (at para. 15) that:
"In order to be 'directly related'', an expenditure must be incurred in the research itself or in the development itself. The amount paid to Deacur & Co. was a consequence of research and development which would already taken place."