"Mr. Walby and Mr. De Las Alas participated in the Global Learning Gifting Initiative program (the “GLGI Program”). Each appellant received two receipts – one for the cash they paid and a second receipt for an alleged donation of educational courseware licences (the “Licenses”). They claimed charitable donation tax credits under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) (the Act) based on both the cash paid and the transfer of the Licenses. Mr. Walby and Mr. De Las Alas were reassessed by the Minister of National Revenue (the Minister) to deny these tax credits. Mr. Walby and Mr. De Las Alas acknowledge that the charitable donation tax credits in relation to the Licenses were properly denied. The only issue before the Tax Court was whether Mr. Walby and Mr. De Las Alas should be allowed to claim charitable donation tax credits based on their cash payments."