The taxpayer sold a timber licence for 16 quarterly instalments for a purchase price whose total amount was fixed, unless the purchaser obtained less that 10,400,000 feet of timber from the lands in question. The amounts paid by the purchaser to the taxpayer were capital receipts to it because the taxpayer had never engaged in logging operations, nor was it part of its business to sell timber licences. It had obtained timber licences solely for the purpose of ensuring that it would have a supply of logs for the operation of its sawmill by granting the right to log the timber to logging contractors.
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