MARTLAND, J.:—The facts involved in this appeal, which are not in dispute, have been fully and completely stated in the judgment of the Exchequer Court and are here restated.

MARTLAND, J.:—I agree with my brother Ritchie that the commissions paid by the appellant to Mr. McFadyn in the years 1951 and 1952 were not taxable in the hands of the appellant. I agree with the conclusion reached by my brother Hall that the

Iacobucci J.:

1 In a narrow sense, this appeal raises one issue: how is a taxpayer to treat a payment made to a prospective tenant for the purpose of inducing that tenant to lease space in the taxpayer's premises? More specifically, is the expenditure, commonly referred to as a tenant inducement payment (“TIP”), to be deducted from income entirely in the year in which it was made, or is it to be amortized over the term of the lease to which it relates?