The taxpayer, an associate professor at the University of Laval, received a subsidy from the University during his sabbatical year (which was mandated by the collective agreement) towards the costs of his sabbatical plan which had as its goal the bridging of research underway in the metallurgical field at the University and at other research centres including the exploration of collaboration possibilities, and also entailed his giving a large number of lectures. The subsidies thus were "grants" (any form of financial assistance paid to a person by a public agency in order to achieve an objective of public interest) (p. 54891) and "research or ... similar work" ("a set of scientific, literary and artistic works and activities having as its purpose the discovery and development of knowledge") (p. 5482).
The research grants net of expenses were includible in the taxpayer's income under s. 56(1)(o).