Goetz,
T.C.J.:
—The
appeals
of
the
estate
of
the
late
Bernard
Zylstra,
file
no.
87-311(IT)
and
of
Robert
E.
Vandervennen,
file
no.
88-314(IT)
were
heard
on
common
evidence.
They
relate
to
income
tax
assessments
for
their
1985
taxation
year.
The
issue
to
be
determined
is
whether
the
appellants
qualify
for
deductions
under
paragraph
8(1)(c)
of
the
Income
Tax
Act.
The
appellants
Bernard
Zylstra
and
Robert
Vandervennen
were
President
and
Director
of
Educational
Services,
respectively,
of
the
Institute
for
Christian
Studies.
The
Institute
provides
post-secondary
education
addressing
sciences
and
humanities
with
a
religious
approach.
It
was
described
in
evidence
as
being
"not
a
religion”
"not
a
denomination”
and
"not
a
church”.
Its
academic
calendar
States
in
part:
Our
approach
is
different
from
a
seminary
or
theological
college
which
is
devoted
primarily
to
training
clergy.
Our
primary
interest
is
to
help
people
in
almost
any
field
of
study
to
understand
their
field
in
a
Christian
way.
We
wish
to
contribute
to
the
preparation
of
people
for
careers,
the
basic
matters
of
which
may
be
related
to
the
studies
offered
by
ICS.
In
this
way
we
may
help
people
to
see
their
work
as
a
Christian
vocation.
It
is
not
a
theological
institute
and
though
it
provides
courses
in
theology,
it
also
provides
graduate
courses
in
philosophy,
aesthetics,
history
and
political
theory.
Many
persons
of
different
denominations
are
members
of
the
Institute.
In
short,
it
is
a
graduate
school
addressing
sciences
and
the
humanities
imbedded
with
solid
Christian
values.
The
responsibility
and
functions
of
the
appellant
B.
Zylstra
as
President
included:
public
relations,
fundraising,
administration,
the
academic
program
and
discipline.
He
represents
the
Institute
with
government
and
other
institutions.
The
appellant,
Robert
Vandervennen
as
Director
of
Educational
Services
is
involved
in
academic
research,
book
publishing,
seminars
and
conferences
on
“theology
of
the
Holy
Spirit"
attended
by
Christian
scholars
from
various
Protestant
denominations.
In
light
of
the
above
facts
I
find
that
neither
appellant
falls
within
the
ambit
of
paragraph
8(1)(c)
of
the
Income
Tax
Act
on
the
basis
of
the
reasons
for
judgment
(unreported)
in
William
J.
McRae
v.
M.N.R.
(87-2273(IT))
and
Jacob
Small
v.
M.N.R.
(87-2269(IT)).
The
appeals
are
dismissed.
Appeals
dismissed.
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