Falcon Equipment Company Limited (Appellant)
v.
Minister of National Revenue (Respondent)
Trial Division, Heald J.—Ottawa, March 2 and
9, 1972.
HEALD J.—This is an appeal from the deci
sion of the Tax Appeal Board rendered on
December 9, 1970 dismissing the appeal by the
appellant from re-assessments for income tax
with respect to its 1960, 1961, 1962 and 1963
taxation years.
The parties have agreed to a special case
stated by consent pursuant to Rule 475.
The question for the opinion of the Court is
whether Middle West Farm Equipment Export
Corporation was at all material times a corpora
tion which was associated with each of the
appellant, Northwest Farm Equipment Limited
and Allied Farm Equipment Limited within the
meaning of subsection (4) of Section 39 of the
Income Tax Act.
This is a companion case to the case of Allied
Farm Equipment Limited and the Minister of
National Revenue and the cases were argued
together. For the same reasons as are stated in
my Reasons for Judgment in the Allied Farm
Equipment Limited case, it is the opinion of the
Court in this case, that Middle West Farm
Equipment Limited was at all material times a
corporation which was associated with each of
the appellant, Northwest Farm Equipment Lim
ited and Allied Farm Equipment Limited within
the meaning of subsection (4) of Section 39 of
the Income Tax Act.
The appeal is accordingly dismissed with
costs payable to the respondent.
You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.