Pratte,
J.A.:
—
We
will
not
need
to
hear
you,
Mr.
Roy.
The
subject
judgment
appears
to
be
based
primarily
on
the
finding
of
the
trial
judge
that
all
the
management
services
needed
by
MSS
Inc.
were
provided
to
it
by
its
own
employees
in
consideration
of
the
salaries
it
paid
them.
The
Court
has
not
been
shown
that
this
finding
was
in
error.
It
follows
that
there
can
be
no
dispute
as
to
the
conclusion
which
necessarily
follows
from
it,
namely
that
the
amount
paid
by
MSS
Inc.
to
G.M.B.D.
Ltée
for
alleged
management
services
was
not
expenses
incurred
for
the
purpose
of
earning
income.
The
appeal
will
therefore
be
dismissed.
Appeal
dismissed.
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