The appellant ("Caithkin") worked as an intermediary in the foster-care system, by finding suitable foster homes for various Children's Aid Societies and placing children there and providing related training and supervisory services. The Societies paid the appellant a per-diem rate, out of which the appellant paid the foster homes. Graham J found that Caithkin had not provided an exempt supply under s. 2 of Part IV of Sched. V, as it satisfied only two of the three requirements of s. 2: