http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/72950/index.do 
Ampomah v. The Queen (July 9, 2014 – 2014 TCC 217 ) was a case heard on common evidence with the McCalla decision:
http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/72119/index.do
As with most of these cases the evidence adduced by the appellant was highly problematic:
[3] Ms. Ampomah testified on her own behalf. In her testimony she indicated that she attended the Jesus Healing Center’s Sunday worship service twice a month commencing on New Year’s Eve of 2005. During 2006, she would attend on Sundays usually for 3 hours of services when she was not scheduled to work that day. Ms. Ampomah does not recall a second floor to the building in which the Jesus Healing Center was domiciled. This became a contentious point with respect to testimony offered by the Respondent’s witness. She would deposit her twice monthly donations in an envelope provided which had the church’s name printed on it and a blank space for a donor to write his or her name. She would donate whatever cash she had on hand, usually around $100, with family members also given money by her to donate. She could not recall what other churches to which she donated, before or after the 2006 period.
[4] Ms. Ampomah also produced bank statements which indicated that she had withdrawn as cash from her bank the sum of $19,020 over the course of the 2006 calendar year. Each entry was identified as an “ABM withdrawal” on the statements. Ms. Ampomah said the withdrawals were not for everyday use, but restricted exclusively to the cash donation for the Jesus Healing Center.
[5] In 2006, Ms. Ampomah earned a net income of $88,713. The sum of $18,200 would have represented 21 percent of her net income in that year as a charitable donation. During that year, she bore other financial obligations as well: she was married and had two children, ages 2 and 1 at the time.
[6] The donation receipt contained certain deficiencies:
a) the charity’s name was spelled incorrectly: namely “Center” as apposed to Centre (its official name registered with the Minister);
b) the date of issuance for the receipt was missing;
c) the locality or place of issuance for the receipt was missing; and
d) lastly, there was no statement that the receipt was “an official receipt for Income Tax Act purposes”.
[7] In addition to the testimony of Ms. Amponah, the evidence of one Mr. Huenemoeder, CRA Team Leader-Charities Audit, indicated that the Jesus Healing Center had failed to keep any meaningful books and records, issued 3 million dollars in donation receipts in just over 2 years, but only deposited some $18,000 into its bank accounts during the same period. The pastors of the Jesus Healing Center, during an interview with the Team Leader-Charities Audit, admitted that no sum ever approaching the 3 million dollars was received by the Jesus Healing Center and that charitable donation receipts were fabricated. Although some donations were received, the amounts were a small fraction (less than 7%) of the amounts receipted. No donation envelopes, receipt records or other evidence of any donations were ever produced or revealed during the CRA Audit. None of the 400 purported donors could provide collaborative or supporting proof of the donations.
The court rejected the appellant’s submissions:
[19] The present case is quite similar. There is no sense to the notion that a married person with 2 children, paying a mortgage, making the Appellant’s salary donated $18,200 in cash in one year to a church she attended with her family, but would call no witnesses to verify the donations and have so little regard to documenting the specific amounts, the dates and the record keeping for such sums.
[20] While some nominal donations may have been made, on the basis of the evidence and the balance of probabilities on which the matter must be decided, there is no plausible reason to conclude that any amount coming close to $18,200 was given in 2006 by the Appellant to Jesus Healing Center.
[21] For these reasons, the appeal is dismissed.