Judson, J (all concur):—The issue in this appeal is whether the appellant taxpayer, Stewart & Morrison Limited, in computing its income for the fiscal period ending June 30, 1966, is entitled to deduct as an expense an amount of $72,345. It had written off this amount as a bad debt in respect of loans which it had made to its wholly- owned American subsidiary. These loans were made during the period March 1964 to April 1966. The Tax Appeal Board decided in favour of the taxpayer ([1969] Tax ABC 65).