STEWART, J.:—On the 27th day of December, 1941, Harry Clifford Hatch entered into an agreement with The Toronto General Trust Corporation as trustees and Willisted Limited, whereby the last named corporation transferred to the trustee on the date of the agreement

KERWIN, C.J. (concurred in by Fauteux, J.) :—The respondent claims from the appellant, the Steel Company of Canada, Limited, a sales tax on the sale price of certain goods manufactured by the appellant in Montreal and delivered by it to Canada Steamship

CAMERON, J.:—This is an appeal from a decision of the Income Tax Appeal Board dated May 18, 1954, whereby the appellant’s appeal from an assessment for the taxation year 1952 was dismissed.