Crystal Beach Park Limited v. The Queen, 2006 DTC 2845, 2006 TCC 183 -- summary under Paragraph 251.2(2)(a)

By services, 17 July, 2024

In finding that two business associates (Tiburzi and Gelder) were not a group of persons, Sheridan J. noted that their past business dealings with each other had not engendered the kind of relationship that might cause one or the other of them to be able to influence the other to vote in accordance with his wishes, and that there were no agreements by them to act in concert. Accordingly, they did not represent a group that had acquired control of the taxpayer.

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2 business associates were not acting in concert and were not a group
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