Saskatchewan Wheat Pool v. The Queen, 2008 DTC 2520, 2008 TCC 8 -- summary under Capital Loss v. Loss

A corporation ("MAALSA") that was jointly funded by the taxpayer and two other provincial wheat pools transferred vacant land held by it to the taxpayer and the other wheat pools in satisfaction of debt that represented over 10 times the fair market value of the transferred property. Bowman, C.J. found that although the cost to the taxpayer of the land acquired by it was deemed by s. 79.1(6) to be equal to the amount that was owing to it, the land was acquired by the taxpayer on income account given that the Pools intended to sell the property as soon as possible after it was surrendered to them and that this transaction gave rise to an accounting profit. Furthermore, if attention were paid to the entire sequence of events, this did not help the taxpayer as the circumstances established MAALSA also held the land as inventory.