Daishowa‑Marubeni International Ltd. v. Canada, 2013 DTC 5085 [at at 5959], 2013 SCC 29, [2013] 2 SCR 336 -- text

Minister of National Revenue v. Sedgwick, 63 DTC 1378, [1963] CTC 571, [1964] S.C.R. 177 -- text

MARTLAND, J. (concurred in by Abbott, Judson and Hall, JJ.) :—On March 31, 1949, the respondent, along with four other parties, entered into an agreement with John Edward Purcell, pursuant to which they advanced funds to Purcell to enable him to purchase

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