Shares of a corporation ("Clairvoyants") that the taxpayer tendered to a bid for all the shares of Clairvoyants were not disposed of by it until the date that the bidder took up and paid for the shares. Noël J.A. stated (at para. 50):
"It would clearly be contrary to the purpose of the legislation governing [public share offerings], and contrary to the intention of the parties, if the offeror was to be entitled to the fruits and income from the shares before he paid the price thereof."