Ferrel v. R., 97 DTC 1565, [1998] 1 CTC 2269 (TCC) -- text
Mogan T.C.J. :
Mogan T.C.J. :
Sopinka J.:—
RAND, J.:—The respondent is what is called the administrator of an investment trust. It raises money, purchases securities which it places in the custody of a trustee, in this case a corporate body, and disposes of certificates representing fractional interests in