Before concluding that a subsidy received by the taxpayer from the federal government, pursuant to a statute, for the construction of a dry dock was a capital receipt, Thorson P. indicated that (at p. 669-670):
"The appellant was not entitled to receive nor did receive the subsidy in the course of its trade or business operations or because of them ... . There was no guarantee of trade or business profits earning nor was the subsidy given to supplement or increase the operational revenues of the appellant. Indeed, the subsidy payments had nothing to do with the trade or business operations of the appellant at all."