Can a management fee be claimed as an allowance for tax?

I wish to make clear that, in referring to the refusal to make an allowance for tax in Andrews v. Grand & Toy, I do not express a view on the question whether such an allowance can be made as a matter of law. A claim for such an allowance was made in this case at trial. The trial judge expressed reservations whether it is allowable but based her refusal to make an allowance on the ground that, in any event, the evidence was insufficient to provide a basis for determination. No appeal has been taken from that and so no issue with respect to such an allowance is before us. However, in my view, there is an analogy between the basis on which that allowance was refused in Andrews v. Grand & Toy and some of the difficulties inherent in the claim for a management fee allowance.