Ozawa v. R., 97 DTC 1500, [1998] 2 C.T.C. 2035 (TCC) -- summary under Subsection 15(2.6)

By dwpv, 28 November, 2015

Before going on to find that amounts advanced by a corporation to the taxpayer had not been eliminated by way of set-off against amounts allegedly advanced by the taxpayer to the corporation, Sarchuk TCJ. stated (at p. 1503) that the Gannon decision (88 DTC 1282) "stands for the proposition that there is a requirement of an agreement or contract calling for the mutual liquidation of the indebtedness and that this requirement is mandatory".

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