Stefanson Farms Ltd v. The Queen, 2009 DTC 177, 2008 TCC 682 -- summary under Substance

An agreement dated October 16, 1998, with an effective date of January 1, 1998, between the taxpayer and shareholder which provided for the purchase by the taxpayer or the shareholder's 99% interest in a partnership, and a January 3, 1998 agreement for the purchase by the taxpayer of the remaining 1% interest in the partnership, were not documents that the taxpayer was now permitted to disavow on the basis that they did not reflect the true state of affairs. The Courts have given short shrift to such taxpayer arguments.