The taxpayer was unsuccessful in his attempt to establish that a loan received by him from a controlled corporation (Lemoine Inc.) was in fact a loan from a customer of Lemoine Inc. which had lent the money to fund the loan from Lemoine Inc. to the taxpayer. In particular, Tremblay TCJ. noted that there had been a failure to establish that the terms for repayment applicable to the two loans were the same or virtually the same, and were respected.
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