A Quebec air traffic controller received from his employer, the federal government, the sum of $15,571 to compensate for house mortgage expenses that he might incur outside Quebec, and the sum of $2,155 which was computed as a percentage of his income, as part of a Department of Transport policy to seek to relocate controllers with anglophone ancestry to outside Quebec so as to avoid labour relations problems. The sum of $15,571 was not received by the controller in respect of his employment. The payment "was primarily motivated by considerations extraneous to the employment, namely public and labour relations considerations". Secondly there was no benefit to the controller (albeit he was under no obligation as to how he should spend the sum) because the effect of the payment of the sum was merely to partially reimburse him for the capital loss he incurred on his relocation. Although the sum of $15,571 was thus non-taxable, no proof was put forward by the controller "to show that he actually suffered other losses due to his relocation equal to the $2,155.41 he received, and a benefit accordingly accrued to him under s. 6(1)(a) in respect of this amount".