ABBOTT, J. (all concurring) :—The issue in this appeal is whether the appellant company was ‘‘associated’’ during the 1961 and 1962 taxation years with a second company, Strad- wick’s Limited, within the meaning ‘of Section 39 of the Income Tax

JUDSON, J. (all concur) :—The sole question in this appeal is whether a profit of $263,864.03 was properly assessed in the taxation year 1955. The judgment of the Exchequer Court holds that this profit must be excluded in assessing the profits for the

McDonald J.A.:

The issue to be decided in this case is whether a company, such as Pardee Equipment Limited (the “Respondent”), may claim inventory allowance deductions under s.20(1)(gg) of the Income Tax Act (the “Act”) for goods, the title of which is held by another company, while many of the other incidents of ownership are vested in the taxpayer. In other words, what proprietary interest is required before goods held for sale by a taxpayer may properly be considered its “inventory”.