http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/64468/index.do 
Vo v. The Queen[1] (October 28, 2013) involved a taxpayer’s claim to charitable tax credits arising out of a completely bogus arrangement:
[5] In 2009 the CRA began an investigation into an extensive charitable donation scam that was masterminded by two individuals, Festus Bayden and Eric Armah. The scheme involved the preparation of tax returns claiming false donations. The CRA estimates that just under $10 million of bogus tax reductions and refunds were claimed. Bayden fled the jurisdiction; Armah pled guilty and was sentenced to three years in prison.
[6] The transcript below, from Armah’s criminal proceeding, describes the essential aspects of the scheme.
The scheme operated as follows: Taxpayer clients attended at E&F to have their tax returns prepared. Eric Armah or Festus Bayden indicated to their clients that the client could get a larger refund or pay reduced taxes if the client made a charitable donation to a certain charity; the larger the charitable donation the greater the refund or reduction in taxes. This charitable donation was false in the following manner: The client paid Bayden and Armah for this charitable donation in an amount far less than what actually appeared on the charitable donation receipt or on the tax return as the amount claimed. Armah and Bayden charged their clients approximately 10 percent of the face value of the false charitable donation amount claimed on each return. This is the amount the clients actually paid for their false charitable donations. Armah and Bayden also generally charged each client an additional $40 to $50 for the preparation of each return.
When required Bayden and Armah provided their clients with false charitable donation receipts in support of donation credits reported. These donation receipts were in the names of various charitable organizations including, but not limited to: International Aid and Support Organization, Ave Development Foundation, Jesus is the Answer, The Redemption Power International Ministry, Jesus Healing Center, All Nations Full Gospel, City Chapel Ministries International, Peace Light Ministries, Liberty Parish, Canafrica International Foundation, Redeemer’s Victory Church and Pentecostal Assembly Church International and Christ Power Mission.
The court was highly critical of the taxpayer:
[12] First, Mr. Vo stated that the donations were not made in the particular taxation year at issue but in the following year. Accordingly, if donations were made, they were made in 2005 and 2006. Since no donations were made in 2004, the appeal with respect to this taxation year should be dismissed.
[13] Second, the evidence reveals that the Foundation was likely not a registered charity during the relevant taxation years. The Foundation only became registered in the following year. This is sufficient to dispose of the appeal for both taxation years.
[14] Third, at the hearing Mr. Vo changed the position that he had previously taken in his notice of objection and his notice of appeal. Not only were the amounts that Mr. Vo paid a fraction of what was first alleged, but also Mr. Vo falsely represented in his notice of appeal that he was satisfied with the bona fides of the donations because he checked the charitable status of the Foundation on the CRA’s website. Mr. Vo acknowledged at the hearing that this was not true. This calls into question the reliability of Mr. Vo’s testimony as a whole to the extent that it was not supported by other evidence.
[15] Fourth, there is no evidence that any of the cash that Mr. Vo paid found its way to the Foundation or to a charitable organization. Most, if not all, of these funds were likely pocketed by Bayden and Armah.
[16] Fifth, in his testimony Mr. Vo painted a picture of someone who did not understand any of the tax aspects of the scheme. He said he simply wanted to help poor children in Africa. This testimony was simply not credible. Mr. Vo was involved in a scheme that involved a substantial reduction in tax. He also made false statements in the notice of objection and the notice of appeal. I do not believe Mr. Vo’s testimony that he had a charitable purpose and that he had no knowledge of the tax implications of the scheme.
[17] Mr. Vo has the burden to establish that gifts were made to a registered charity. He has not satisfied this burden.
Under the circumstances the taxpayer was probably lucky that the court did not use harsher language.
[1] 2013 TCC 343.