The appellant, a registered charity, operated a summer lakeside camp which provided camp experiences for younger and older children, as well as seniors’ and family retreats. The attendants were mostly evangelical Christians. Bell JTCC found (at para. 31) that “the Appellant's sole purpose was the conduct of a Christian camp including evangelising for the conversion of persons to the religious beliefs it espoused.” In finding that the camp was not a place of amusement, he stated (at para. 34):
It is noted that the words "the purpose" are employed. This indicates that the sole purpose of the "place of amusement" was to provide amusement or recreation. Words such as those used in subsection 55(2) of the Income Tax Act, namely, "one of the purposes of which" are not used in this definition.