Woods J allowed the deduction under s. 118.2(2)(h) of travel expenses for the taxpayer's almost daily trips between Weyburn and Regina to assist with his spouse's recovery from brain damage, which required extensive therapy. There was solid evidence that the taxpayer's daily presence contributed significantly to her recovery.
Bell (2009 DTC 1342, 2009 TCC 523) concluded that 118.2(2)(h) includes travel costs of a spouse who accompanied the patient and lived away from home during the period of treatment. Woods J stated that this interpretation was "a very reasonable one in the context of a broadly-worded and ambiguous provision" (para. 12).