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a balance of $687,499.91. On July 2, 1993,9 after the actions
described below which took place on June 30 and July 2, 1993,
ITC’s Royal Bank account balance was the same amount as it was on
June 30, 1993, except for reductions attributable to an overdraft
interest charge10 and the clearing of checks unrelated to the
actions described below. The balance in petitioner’s Royal Bank
account, number 302-0402-4 (petitioner’s Royal Bank account), was
the same before and after the actions described below.
On June 30, 1993, Royal Bank received a letter (June 30,
1993 letter) from Louis G. Neumann (Mr. Neumann), petitioner’s
vice president, secretary, and general counsel and ITC’s vice
president and secretary. The June 30, 1993 letter stated in
pertinent part:
In confirmation of our recent conversation it is hereby
requested that you affect [sic] the following transac-
tions on behalf of InterTAN Inc. [petitioner] and its
subsidiary InterTAN Canada Ltd [ITC]:
1. The sum of US$20,000,000.00 is to be advanced to
InterTAN Canada Ltd. by Royal Bank and deposited
to account number 302-8529-6.
2. The enclosed cheque [dated June 29, 1993] in the
sum of US$20,000,000.00 drawn on account number
302-8529-6 [ITC’s Royal Bank account] and made
payable to InterTAN Inc. is to be deposited in
InterTAN’s account number 302-0402-4 [petitioner’s
9July 1, 1993, was Canada Day, a federal and bank holiday in
Canada.
10The $3,552.67 overdraft interest charged to ITC on July 2,
1993, was reversed on July 16, 1993, and new overdraft interest
charges in the amounts of $101.48 and $12,211.91 were imposed.
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