Whitland Construction Co. v. The Queen, 99 DTC 33, [1999] 1 CTC 2172 (TCC) -- text

Teskey T.C.J.:

The Appellant appeals its reassessment of income tax for its taxation years 1991, 1992 and 1993.

Issue (L8/R5201/T0/BT0) test_marked_paragraph_end (1684) 1.024 0347_8034_8166

The sole issue is whether the Appellant in computing its income for its 1991 taxation year is entitled to deduct the amount of $1,701,375 as a bad or uncollectable debt under subparagraph 20( 1 )(p)(ii) of the Income Tax Act (the “Act”).

For this question, paragraph 20( 1 )(p) reads:

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