Woodward Stores Ltd. v. The Queen, 91 DTC 5090, [1991] 1 CTC 233 (FCTD) -- summary under Expense Reimbursement

The taxpayer, which was a well-known general merchandiser operating 24 department stores in Western Canada, negotiated and received "fixturing allowances" of $3,000,000 and $750,000 on leasing premises for two stores in Red Deer and Calgary. The actual amounts expended on fixtures exceeded the allowances. Joyal J. found, in light of the fact that the inducements were applied to capital improvements and in light of the accounting treatment of the payments (which was to credit them to the cost of the improvements) that they were tax-exempt receipts.