A forgiven amount arose in respect of the indebtedness of the taxpayer for unpaid contribution amounts to a partnership at the time that he entered into an agreement settling the claim of the general partner against him for those amounts, rather than at the time he paid the amount owing by him pursuant to the Settlement Agreement. The amount of the forgiven amount was not simply the difference between the amount owing by him for unpaid contributions and the amount paid by him, but rather was reduced further by the value of the rights in the form of potential claims he had against the general partner that he gave up by entering into the Settlement Agreement.
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forgiveness at time of settlement agreement
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d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
338882
Extra import data
{
"field_legacy_header": "<strong><em>Richer v. The Queen</em></strong>, 2009 DTC 1413, 2009 TCC 394",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}
"field_legacy_header": "<strong><em>Richer v. The Queen</em></strong>, 2009 DTC 1413, 2009 TCC 394",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}
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Workflow state