Receipt Argument

"The appellants argue that the two receipts—one for the cash and the other related to the Licenses—should have been treated separately. They submit that there is no statutory mechanism in the Act for combining receipts and determining their combined legitimacy. Their argument focuses on the receipts and is essentially that because Mr. Walby and Mr. De Las Alas each received receipts for the cash they paid, separate and apart from the receipts based on the Licenses, they should be entitled to a tax credit based on the cash paid. The argument is that the Court should look no further than the receipt and, once the taxpayer establishes that the amount indicated on the receipt was paid, the taxpayer is entitled to claim the charitable donation tax credit. However, while a receipt is a requirement to obtain a tax credit under subsection 118.1(2) of the Act, the receipt alone does not establish the gift. It is simply evidence of the gift. The entitlement to a tax credit is found in subsection 118.1(3) of the Act, which provides that a tax credit is based on an individual’s total gifts for a year. “Total gifts” is defined in subsection 118.1(1) of the Act and includes an individual’s total charitable gifts, including the eligible amount of a gift made to a registered charity."