Under an agreement with the School Board (which previously provided student free transportation), the parent was required to personally arrange for the transportation of the child in consideration for a specified daily sum received from the School Board as a transportation allowance. In finding that these receipts were not income, CRA stated:
[W]here a payment is a reimbursement of personal expenses, it is our view that the payment would not be taxable.
Although the transportation allowance in this situation is not strictly speaking a reimbursement of expenses … it is intended to compensate parents for an expense that would normally be borne by the … Board and not to generate income to them.