MNR v. Colford Contracting Co. Ltd., 60 DTC 1131, [1960] CTC 178 (Ex Ct), briefly aff'd 62 DTC 1338, [1962] CTC 546 (SCC) -- summary under Paragraph 12(1)(b)

Holdbacks on contracts for the installation of heating and plumbing systems became "receivable" when the architect's or engineer's certificates were executed, thereby resulting in an absolute entitlement of the taxpayer to receive the holdbacks at a later due date. "[I]t is not enough that the so-called recipient have a precarious right to receive the amount in question, but he must have a clearly legal, though not necessarily immediate, right to receive it."