47.3% of a multi-purpose building which was constructed for a computer graphics corporation was used exclusively by it for scientific research. The corporation was unsuccessful in deducting 47.3% of the construction costs that related to common and administrative areas that were not used solely for scientific research purposes and in the deduction of 47.3% of expenses of a current nature that related to the common areas. McGillis J. stated (p. 6494):
"Even assuming that some leeway is permitted from the 90% rule adopted by the Department ... a 47.3% portion of expenditures incurred in relation to SR&ED would not fall within the meaning of the words 'all or substantially all'."