Jorré found that the taxpayer and her husband were carrying out their garden centre business in equal partnership. He stated (at paras. 36-37):
Both spouses made contributions. The appellant gave up her existing job and worked at the garden centre; the husband worked at the garden centre. Property belonging to both of them was used to guarantee a loan. One or both took out the loan.
Both spouses could write cheques, both had access to the business account and both used money from the account to pay family expenses.