O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295 -- summary under Section 96

By services, 28 November, 2015

A partnership in which the taxpayers invested was found (at para. 105) not to be a valid partnership under s. 96 as "the transactions were structured so that it was virtually impossible for the Partnership revenues to meet the debt levels and consequently there was no intention to earn a profit even as an ancillary purpose".

Topics and taglines
Topic
Income Tax Act - s. 96
Tagline
not a partnership since no ability to generate profit
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
339690
Extra import data
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