Beaubier
T.C.J.:
On
October
24,
1997
the
Appellant
moved
to
reopen
judgment
in
this
matter
on
the
basis
that
he
had
failed
to
change
his
address
for
Court
purposes
and
therefore
did
not
receive
notice
of
the
hearing
in
which
default
judgment
was
granted
against
him.
There
was
no
opposition
from
the
Respondent
and
the
motion
was
granted.
Thereupon,
on
the
consent
of
the
parties,
the
matter
proceeded
to
a
hearing
on
the
issues
pursuant
to
the
Informal
Procedure.
The
Appellant
was
the
only
witness.
The
Appellant
has
appealed
a
disallowance
of
a
claim
to
deduct
child
care
expenses
for
his
1994
taxation
year.
Paragraph
5
of
the
Reply
to
the
Notice
of
Appeal
reads
as
follows:
5.
In
so
reassessing
the
Appellant,
the
Minister
made
the
following
assumptions
of
fact:
(a)
the
Appellant
did
not
incur
child
care
expenses
(referred
to
above
and
hereinafter
as
the
(“Expenses”)
in
the
1994
taxation
year;
(b)
the
Appellant
has
not
proven
the
alleged
Expenses
as,
or
on
account
of,
child
care
expenses
by
filing
with
the
Minister
one
or
more
receipts,
each
of
which
was
issued
by
the
payee
and
contains,
where
the
payee
is
an
individual,
that
individual’s
Social
Insurance
Number;
The
Appellant
has
claimed
the
amount
of
$6,000
as
a
deduction
in
his
1994
taxation
year
although
he
failed
to
file
any
receipts
or
the
Social
Insurance
Number
of
the
person
whom
he
testified
cared
for
the
children.
The
Appellant
stated
that
the
caregiver
was
a
13
year
old
girl
whose
first
name
was
“Catherine”.
He
testified
that
he
gave
the
last
name
of
the
girl
to
Revenue
Canada.
He
also
asked
the
girl
for
a
receipt,
but
her
parents
did
not
permit
her
to
give
one
to
him.
He
believes
that
the
girl
had
no
Social
Insurance
Number
on
account
of
her
age.
His
testimony
is
that
Catherine
provided
child
care
for
his
10
year
old
and
7
year
old
children
from
the
beginning
of
1994
to
the
end
of
the
academic
year,
1994.
In
the
fall
of
1994
he
found
a
registered
day
care
centre
to
care
for
the
children.
The
essence
of
what
he
has
stated
to
the
Court
is
that
he
paid
a
13
year
old
$1,000
in
cash
per
month
to
provide
after
school
care
for
his
two
children.
He
offered
no
supporting
evidence
for
this
although
he
did
say
that
his
bank
book
would
show
regular
withdrawals
of
appropriate
sums.
There
are
currently
decisions
of
this
Court
going
both
ways
on
the
question
as
to
whether
or
not
the
requirements
of
receipts
and
a
Social
Insurance
Number
contained
in
section
63
of
the
Income
Tax
Act
are
mandatory
or
directory.
However,
in
this
case,
it
is
not
necessary
for
the
Court
to
enter
into
a
review
of
that
law.
Without
some
corroborating
evidence
from
the
Appellant
such
as
receipts
and
a
Social
Insurance
Number
or
the
testimony
of
the
13
year
old
girl
Catherine
(who
would
now
be
16
or
17)
to
the
effect
that
she
was
babysitting
the
Appellant’s
children
and
was
paid
the
wages
described,
the
Court
does
not
accept
the
Appellant’s
testimony
by
itself
to
the
effect
that
he
paid
a
13
year
old
girl
$6,000
in
cash
in
1994
for
the
services
already
described.
The
principle
of
section
63
is
that
corroboration
is
required.
Certainly,
in
the
circumstances
of
this
case,
the
mere
testimony
of
the
Appellant
is
not
enough
to
overcome
the
assumptions
without
corroboration.
The
appeal
is
dismissed.
Signed
at
Ottawa,
Canada,
this
28th
day
of
October,
1997.
Appeal
dismissed.
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