An organization set up by the Saskatchewan government to assist the agricultural industry tested a combine for approximately 115 hours (roughly 0.5% of its expected useful life) while title remained with the manufacturer and prior to its delivery to the purchasing taxpayer (a farmer). Bowman A.C.J. found that the combine had not been used for any purpose whatever at the time of its acquisition by the taxpayer, and stated (at p. 1020):
"Testing new equipment by or at the behest of the manufacturer is an essential part of the manufacturing process."