OGILVIE v KITTON (Surveyor of Taxes).(1) (1903-1911) 5 TC 338
NO. 296.–COURT OF EXCHEQUER (SCOTLAND).–SECOND DIVISION.–
3rd, 4th, and 17th June, 1908.
Income Tax, Schedule D. First Case. – Business abroad. – Appellant, who resides in Aberdeen, is the sole owner of a business of woollen warehousemen carried on by managers on his behalf at Toronto, Canada. Appellant alone is entitled to the profits and liable for the losses in connection with the business, and it is found as a fact by the District Commissioners that he is vested with the sole right to manage and control every department of its affairs.