In finding that the meaning of "full-time" employment should have a consistent application, Noël, J.A. stated (at para. 13):
Defining "full-time employment" to be equivalent to the standard number of hours worked in an industry and area where the activities take place ... is inconsistent with the scheme which is to ensure that a certain minimum level of activity exists in a corporation prior to allowing it the small business deduction. Such a test would lead to differing criteria for "full-time employment" between industries and regions. Section 125 would thus be applied in an inconsistent and subjective manner, violating the principle that similarly situated taxpayers should be taxed equally.