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Pursuant to the Income Tax Act, an inter vivos trust is deemed to dispose of its capital property at fair market value on the 21st anniversary of its date of settlement.

Richard Homburg's $1.16 million stock option deduction was denied after the Tax Court found his company's own securities filings contradicted his claim of arm's length dealing. The case demonstrates how corporate disclosures made to investors and regulators can become decisive evidence in tax disputes, even when ownership structures appear to support a taxpayer's position.