The corporate taxpayer obtained financing from a bank to acquire new buses.
The Minister of National Revenue reassessed the taxpayer, including this indebtedness as part of its capital under s. 181.2(3) of the Income Tax Act.
The Tax Court of Canada and the Federal Court of Appeal upheld the reassessments.
The Supreme Court of Canada dismissed the taxpayer's appeal, agreeing with the reasons of the Federal Court of Appeal regarding the relations between the parties.
