The income tax consequences to a corporation of carrying on business through an agent (a management company) were identical to those of carrying it on through employees, so that the taxpayer's activities qualified as an active business. The Court stated (at p. 6159):
[T]here is [no] material difference in principle, in so far as the carrying on of an active business by a corporation is concerned, between carrying it on through the agency of officers or servants of the corporation and carrying it on through the agency of an independent contractor.