Transport M.l. Couture v. The Queen, 2003 DTC 817 (TCC), aff'd sub. nom. 9044-2807 supra. -- summary under Subsection 256(5.1)

The taxpayer was found to be controlled within the meaning of s. 256(5.1) by another corporation ("Transport Couture") given the economic dependence of the taxpayer on Transport Couture and the operational control of Transport Couture (the taxpayer had no employees, all management and other personnel services were provided to it by Transport Couture and Transport Couture was its only customer) and given that Transport Couture was owned indirectly by the five sons of the sole shareholder of the taxpayer, who was in declining health and who relied on his sons.