In finding that fees paid to an accounting firm to prepare investment tax credit claims in respect of scientific research undertaken by the taxpayer did not qualify on the basis that they were "a legal or accounting fee", Mogan D.J. stated (at para. 882):
"Those services are within the scope of what an accountant ordinarily does for a fee. Filing a claim for an investment tax credit is part of filing an income tax return if the taxpayer is engaged in SR&ED."