The taxpayer was a member of the Toronto International Celebration Church ("TICC"), an evangelical church of over 2000 members with no formal hierarchy. In finding that the taxpayer was a member of the clergy, V.A. Miller J. referred to the "spiritual leader" requirement in Kraft, and stated (at paras. 22-24):
I take it that a spiritual leader is one who is aimed not so much at directing people or organizing people but is aimed at changing people. It is someone who not only prays with those in need but offers them spiritual guidance.
It was [the head pastor's] evidence that the Appellant "did everything that he did except give sermons on Sundays." ...
The Appellant oversaw the leaders in the TICC. I find that she was a spiritual leader in the TICC and she was recognized as such by the congregation and the senior pastor of TICC.
The taxpayer also "ministered" to the congregation.