Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82 -- summary under Timing

Taxi owners contracted with the taxpayer to pay the taxpayer $500 per taxi for the privilege of operating their taxis within the taxpayer's association. On the basis of a finding that the $500 paid was a deposit or joining fee and would become the absolute property of the taxpayer only if the particular owner withdrew from the association and the parties failed to agree on a satisfactory replacement for him, the $500 did not constitute income to the taxpayer.