Létourneau J.A. for the court at para. 6 (official translation):
The services rendered by the appellant were done so [sic] at his customer's place of business situated off the reserve where, according to the evidence, he had his office and worked at least eight (8) hours a day, every business day. It was neither erroneous nor unreasonable for the judge to find that the income had been earned off reserve. We agree with the judge that the fact that the appellant lived on the reserve and had an office in his home does not obliterate the [finding].