Bédard J found that the taxpayer, wholly owned by an individual ("Almeida"), was operating a personal services business, given that:
- the taxpayer's compensation was limited to $69.33 per hour that Almeida worked;
- the taxpayer's two clients provided the tools; and
- Almeida was closely controlled by the clients, including that he could not choose where to work and that he reported to a team leader.