LOCKE, J. (concurred in by Taschereau, Estey, Cartwright and Fauteux, JJ.) :—This is an appeal from a judgment of Archibald, J., dismissing the appeal of the present appellant from an assessment made under the Excess Profits Tax Act, 1940

THE Chief Justice:—On February 6, 1932, James E. Wilder, the appellant, sold to Wilder Norris, Limited, properties consisting of land, buildings, real estate, securities, listed in fourteen schedules appended to an agreement of that date. In effect, Wilder was thus