In finding that the taxpayer was entitled to deduct capital cost allowance in respect of houses situated close to the taxpayer's greenhouse operation and occupied by employee-shareholders of the corporation (all of whom had similar religious beliefs), Bowman, C.J. stated (at para. 23-24):
Once I conclude that it is a business decision to house the employees in company-owned houses and to provide other facilities in the Commons it is not up to me or the Minister to question that decision, even if I were to disagree with it, which I do not... . This case is an excellent example of the CRA seeking to substitute its business judgment for that of the taxpayer.