In 1961 the taxpayer purchased over £5 million of oxo-alcohol from a U.S. affiliate for a deferred U.S.-dollar purchase price. The subsequent devaluation of the Canadian dollar and a decline in commodity prices, which indicated that the taxpayer would suffer a loss on the resale of the inventory and possible insolvency, prompted the U.S. affiliate to forgive a portion of the indebtedness in 1962, which the taxpayer took into his accounting income for that year.
In finding that the cost of the inventory which the taxpayer had on hand at the beginning of its 1962 taxation year (and which initially had been recorded at a cost based on the exchange rate on the date of purchase) was reduced by the appropriate portion of the amount of the forgiveness, Walsh J. stated (p. 5303) that the taxpayer:
"as a result of this forgiveness of debt, was enabled to make a profit in the 1962 taxation year which is before me rather than suffering a loss which was otherwise inevitable and that it should, accordingly, pay the appropriate taxation on this profit."