The appellants appealed reassessments disallowing the deduction of travel expenses and licence fees in computing the corporate appellant's business income, and including the disallowed travel expenses in the individual appellants' incomes as shareholder or employee benefits.
The Tax Court of Canada dismissed the appeals, finding that the appellants failed to adduce credible evidence to demolish the Minister's assumptions that the travel expenses were personal in nature and not incurred for business purposes, and that the licence fees were not incurred by the corporation.
