After noting that a Revenue Canada auditor who was reviewing the taxpayer's SR&ED claims, seemed "to have been unwilling to consider any evidence which was not presented to him in the form which he preferred", Bonner T.C.J. went on to note (at p. 2375):
"The onus which must be discharged by a taxpayer who appeals from an income tax assessment is decreased in weight where, as here, the assessment rests on an investigation which is affected by an attitude problem."
(The taxpayer nonetheless failed to establish that its software development project was not routine.)