There was a sufficient degree of control by the Seventh-Day Adventist Church in Canada of the Canadian Union College, and by the Western Christian College Society of the Western Christian College for the president of each such college to qualify as being appointed by a religious denomination.
However, a professor of religious knowledge at the Canadian Union College did not qualify for the deduction as it could not be said that his students represented a congregation. Bowman TCJ. stated (at p. 727):
"Nor do I think that a group of students can be said to be a congregation in the sense of an assemblage or gathering of persons to whom a minister provides spiritual counselling, advice, illumination and inspiration."