Parkland Operations Limited v. Her Majesty the Queen, 90 DTC 6676, [1991] 1 CTC 23 (FCTD) -- summary under Income-Producing Purpose

A loss of $563,396 which the taxpayer suffered from defalcations made by minority shareholders was found to have resulted from wrongful draw-downs from the taxpayer's operating lines of credit in the course of the taxpayer's trading operations, and therefore was realized by it on income account. The minority shareholders "misappropriated the money while dealing with it in the course of the company's activities, and not by exercising some overrriding control over the funds which existed outside of those activities" (p. 6680).