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    <description>Waiver of a loan advanced under a shareholders&#039; agreement was treated as a revenue loss where the advance remained contractually repayable from business surplus and formed part of the taxpayer&#039;s established business activities as partner, shareholder and financier. Sustained losses led to an irrevocable settlement waiver. Because the advance neither acquired a capital asset nor amounted to mere shareholder funding, it was distinguished from advances for acquiring immovable property. Monies advanced in the ordinary course of business could be written off under section 36(2) of the Income-tax Act, making the waived amount allowable as a business loss.</description>
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