Issues

"The appellants, in paragraph 9 of their memorandum, frame the issues as follows:\n\n1) The Tax Court judge erred in finding that the donation to the registered charity was not a valid gift.\n\n2) The Tax Court judge erred in finding that the split gifting rules operated to vitiate a valid gift.\n\nThe issues, based on the arguments made by Mr. Walby and Mr. De Las Alas in their memorandum and at the oral hearing, can be reframed as:\n\n(a) did the Tax Court Judge err in treating the transactions as one interconnected series of transactions;\n\n(b) is there a valid gift if, even though a donor may expect to receive something of value, the donor does not actually receive anything of value; and\n\n(c) did the Tax Court Judge err in his interpretation of value for the purposes of subsection 248(30) of the Act?"