The taxpayer, owned and operated by Mr. Mullen, invested in shares and made non-interest bearing loans to a number of corporate ventures to which Mr. Mullen provided management services free of charge by him or the taxpayer. In the course of denying income deductions for these expenses, Miller J. dismissed the taxpayer's argument that, because the expenses were made to produce income from dividends, the expenses related to income from a property rather than a business source. He stated (at para. 73):
[C]learly, the remaining disputed flight expenses relate directly to the business income of the business ventures. The expenses were incurred to make the business ventures profitable. Yes, that might yield at some future point dividend income, but the direct cause and effect link is between the expenses and the business income of the business property ventures, not the relationship with any property source of income.