The Appellant appealed assessments for his 2006, 2007, 2008, and 2009 taxation years, arguing that payments he received for providing caregiving services to at-risk children were exempt from tax under subsection 81(1)(h) of the Income Tax Act, or alternatively, that the Minister was estopped from taxing the income due to representations made by the province of British Columbia.
The Tax Court of Canada found that the Appellant worked as a subcontractor for a business running homes for profit, did not receive social assistance payments based on a means, needs, or income test, and the children did not reside in his principal residence.
The Court also held that the doctrine of estoppel cannot preclude the exercise of a statutory duty.
The appeal was dismissed.
