The taxpayer was a self-employed courier who covered approximately 150 kilometres by foot and public transportation daily in order to deliver various packages. After finding that the taxpayer was entitled to deduct the cost of extra food and water that he needed to sustain himself because of the strenuous nature of his activities, McDonald J.A. stated (at p. 6533):
"Only where there is a corresponding business deduction allowed for fuel in the form of gasoline for the same type of business will a deduction for the extra food and water a human needs to consume as its fuel be allowed. For instance, a rickshaw driver would be entitled to deduct the extra food and drink he needs to consume to do his job because his corresponding compatriot - the taxi driver - is entitled to a deduction for his gasoline."