Mr. L and his wife had acquired several parcels of farm. land and had them farmed under crop leases. In 1955, both being well in their seventies, they incorporated the appellant company by letters patent. The stated object of the company was to carry on the business of farming, and its shareholders were trustees for other members of the family and charities. The company then purchased the land from Mr. L and his wife at an appraised value of $144,000 in return for debentures and promissory notes. The company continued to have the lands farmed under crop leases. During the next few years, the company received the proceeds from the forfeiture of several options to purchase parts of the land and from the sale of part of the land. These monies were used to pay off the debentures and promissory notes. The Minister assessed all the monies received by the appellant Cartwright C.J. and Martland, Judson, Ritchie and Hall JJ. S.C.R.
[19681