A "management fee" paid by the taxpayer, a self-employed real estate agent, to her husband was non-deductible. There was no documentary evidence to support the deduction other than invoices generated on a "totally retrospective" basis following a Revenue Canada audit. Sarchuk J. indicated (at p. 871) that:
There is substantial merit to the Respondent's position that what existed between the Appellant and her husband was nothing more than a domestic arrangement which was not and could not be considered to have created a legally binding agreement between them.