http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/62995/index.do 
Sowah v. The Queen[1] (September 6, 2013) is case dealing with alleged cash donations to the taxpayer’s church:
[2] Ms. Sowah did not appear at the hearing to give evidence, but her husband, Mr. R. Twumasi, acted as her agent and also testified.
[3] Mr. Twumasi explained that, starting in late 2004, he and the Appellant began to attend the Jesus Healing Center, as a friend had recommended it. He claimed that they went every Sunday, and donated $100 or $200 cash each time, sometimes more. According to Mr. Twumasi the Appellant would either put the cash in an envelope at home or in an envelope provided by the church that was tucked in with the hymn book or bible in the row in front. Mr. Twumasi explained his wife would simply just put the cash in the envelope and deposit it in the offertory dish that was passed around.
[4] Mr. Twumasi said that all the donations came from the Appellant’s salary. They would withdraw cash as needed from the bank for domestic purposes, and when they ran out they would simply take out more. The cash for the donations, according to Mr. Twumasi, came from this household money. Mr. Twumasi provided no bank records to corroborate these regular cash withdrawals.
[5] In 2006, Ms. Sowah had income of approximately $86,000 and Mr. Twumasi had income of approximately $8,000. He said he was working that year, though not perhaps for the full year. He was an accountant and was responsible for doing all his wife’s returns. As well as a mortgage, the Appellant and Mr. Twumasi had a line of credit, which currently stands at around $60,000 but Mr. Twumasi could not recall what it was in 2006.
[6] Mr. Twumasi claimed that the Pastor at the Jesus Healing Center, who he named as Edwin Areposo, indicated, as soon as they started going in late 2004 or early 2005, that the church needed money for a new building. It was not until 2006, however, that the Appellant started to make any donations to support the building. No building was ever undertaken.
[7] Ms. Sowah’s charitable giving history from 1997 to and including 2005 was minimal, a few years with nothing at all and the other years averaging approximately $270 a year. Mr. Twumasi alleged they would make donations of a couple of thousand dollars, but would not claim such amounts if they could not readily track down receipts. I found this evidence difficult to accept.
The court held that the receipts tendered by the taxpayer were not technically effective but went on to challenge the very gist of the taxpayer’s husband’s evidence (there being no evidence from the taxpayer herself):
[21] I am also going to address the first requirement – the need for a gift to a charitable organization. I doubt the veracity of the Appellant’s claim of having donated $10,250 for the following reasons:
a) I question Mr. Twumasi’s integrity. He tells me he is no longer suffering any mental impairment from an injury 20 years ago yet admits he continues to claim the disability tax credit every year. On its face, this shows some disregard for requirements of the Act.
b) Mr. Twumasi claims donations were made to help the building fund, yet there was no evidence of any plans for a building. Further, the receipt showed funds were donated for different reasons, none of which were mentioned by Mr. Twumasi.
c) Mr. Twumasi provided no corroboration for the cash payments: no bank records, no ATM withdrawals, nothing.
d) He provided a different name for the Pastor than that given by Mr. Huenemoeder, who interviewed the man. I would have thought that going to a church every Sunday for a couple of years that Mr. Twumasi would have recalled the Pastor’s name.
e) Mr. Twumasi’s claim that money was put in envelopes provided by the church would accord with pews with pouches in them, not with the use of stackable chairs for the congregation. Further, he gave no indication that the Appellant wrote her name on the envelope purportedly provided, so that the church could track the donations. He also provided no sample of the envelope, nor did the audit team come across any envelopes. Mr. Twumasi’s story in this regard simply does not ring true and is not supportable.
…
The court dismissed the appeal – something that was not unexpected on the evidence before the court.
[1] 2013 TCC 297.