Revenu Québec assessed the taxpayer under a cash-flow analysis, as her lifestyle exceeded her income, and she was not forthcoming with Revenu - she maintained that her estranged ex-fiancé paid her living expenses in the relevant period, but would not provide supporting documentation or even, initially, the fiancé's name.
After noting (at para. 20) that a cash flow analysis is a "method of last resort," Masse DJ found that the taxpayer was able to refute the Minister's assumptions, between her oral testimony and that of her ex, who was generally aggressively uncooperative.