Can an appellant receive a credit for inflated tax receipts that are not benefits that vitiate the gift?

Canada (Federal), Canada

The following excerpt is from Herring v. The Queen, 2022 TCC 41 (CanLII):

Justice Woods relied on Canada v. Doubinin, 2005 FCA 298, finding that inflated tax receipts are not benefits that vitiate a gift and that, if there is no benefit, subsections 248(30), (31) and (32) do not apply. She concluded that each appellant was entitled to a tax credit equal to 10% of the face value of the receipt.

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