Campbell J.:

The question in this case is whether Global Communications Limited’s advances to a subsidiary, none of which were repaid, constitute a “bad debt” under s.20(1)(p) of the Income Tax Act, and is, therefore, tax deductible.

A. Agreed facts (L4/R4344/T0/BT1) test_linespace (272>258.02) 1.047 0052_2613_2779

The content of an Agreed Partial Statement of Facts is as follows:

Richard Morneau Prothonotary:

Introduction (L14/R4592/T0/BT0) test_marked_paragraph_end (1498) 1.023 0046_7481_7613

This is an opposition taken under article 597 of the Code of Civil Procedure by three opposing parties to a seizure of movable property carried out on October 11, 1995 in a residence at 4322 Chemin St-Éloi in Jonquiére.