The taxpayer, which was engaged in researching and developing advanced data management and memory management software systems for large mainframe computers, and which had adopted the proxy method for calculating SR&ED expenditures, was able to include in s. 37(8)(a)(ii)(B)(I) the cost of a dedicated telephone line that was used to pass instructions and data from the taxpayer's employees in Ottawa (none of whom left Canada) to the staff of an independent company in Birmingham, Alabama whose mainframe computer the taxpayer was leasing for testing purposes. Lamarre TCJ. stated (at p. 1883):
"Testing would not normally be considered as an eligible SR&ED activity. It becomes an eligible activity only when it is required as part of a systematic experimental investigation, which is the case here."