James Frederick Scott v. Minister of National Revenue, [1963] CTC 176 -- text
Jupson, J. (all concur) :—Both the Tax Appeal Board and the Exchequer Court have found the appellant liable for income tax on certain discounts received in the years 1950 to 1955 inclusive. These receipts came from his purchase of agreements for the sale of land, lease-option agreements on land and mortgages on land. He purchased at a discount and held the securities to maturity. The issue is whether the discounts when received by him were taxable income or accretions to capital.