The appellant appealed an assessment under section 160 of the Income Tax Act, which held her jointly and severally liable for her spouse's tax debt.
The Minister alleged that the spouse indirectly transferred $141,109.38 to the appellant by having his wholly-owned corporations pay for renovations to her residence.
The Tax Court of Canada found that the payments were made without consideration and resulted in a reduction of the spouse's patrimony and an equivalent increase in the appellant's patrimony.
The Court concluded that this constituted an indirect transfer of property within the meaning of subsection 160(1) and dismissed the appeal.
