Foresbec Inc. v. The Queen, 2002 DTC 1786 (TCC), aff'd 2003 DTC 5455, 2002 FCA 186 -- summary under Income-Producing Purpose

At the time of the sale of a control block of the taxpayer, it and the purchasing shareholder "granted" to the vendor a consulting contract for the services of a former executive of the taxpayer associated with the vendor. The payments made under the contract were not deductible given that it was never contemplated that the contract would be implemented and all that it provided for was the obligation to make payments irrespective of the level of services provided.