The respondent taxpayer received $300 from her employer for successfully completing three life insurance courses.
The Minister reassessed her to include this amount in her income.
The Supreme Court of Canada held that while the payment was a benefit in respect of employment under sections 5 and 6 of the Income Tax Act, it also qualified as a 'prize for achievement in a field of endeavour ordinarily carried on by the taxpayer' under section 56(1)(n).
Because the amount was under the $500 statutory exemption limit, it was not subject to tax.
The Crown's appeal was dismissed.