The taxpayers were postdoctoral students who received research fellowships in 2009 from Parkinson Society Canada ("PSC") to conduct research under a University of Ottawa professor. Woods J. ruled that these amounts were indeed fellowship amounts under s. 56(1)(n) rather than grants under s. 56(1)(o). Evidence was sparse, but did show that PSC differentiated between grants and fellowships. Woods J. accepted PSC's characterization of the amounts as being from a fellowship.
She went on to conclude that the amounts were deductible under the fellowship exemption in s. 56(3) then in force. (The definition of "qualifying educational program" in s. 118.6(1) has since been amended to exclude programs that do not confer a degree.)