Slobodrian v. Canada (Minister of National Revenue), 2003 DTC 5632, 2003 FCA 350 -- summary under Total Charitable Gifts

A retired physics professor who agreed to carry out research activities without remuneration pursuant to a contract between Public Works Canada on behalf of the Canadian Space Agency, and the University from which he was retired, was not entitled to a charitable credit for the value of the services performed by him. "The word 'gift' ... in a taxing statute must be taken as referring to what is known to the law as a gift, namely the gratuitous transfer of property (tangible or intangible) ..." (p. 5633), and as the statutory definition of property in s. 248(1) did not expand the word property beyond its normal meaning, the mere supply of services without compensation involved no property and, hence, could not form the subject matter of a gift. Furthermore, he did not provide receipts that complied with Regulation 3510.