The taxpayer's child had a severe learning disability. The taxpayer enrolled her at a private school, where she received special attention from one teacher, who she started and ended each day with, quiet rooms for studying when she was not in class, computer equipment, and a special education plan based on her doctor's report.
Nevertheless, Bowie J. found that the taxpayer's expenses for tuition and course materials could not be deducted from income. As per Scott, the expense of the child attending the institution must be inextricably tied to the specific needs of that child. He stated (at para 9):
In plain English, GNS is not a special school for handicapped or learning disability children. It is an academic institution that prepares its students for the rigour of a university education. It is, however, capable of accommodating those children who meet its admission standards, but have physical or learning disabilities.