Before going on to find that the taxpayer was the beneficial owner of equipment title to which was held by a finance company that received lease payments from the taxpayer, Bowie J. stated (at para. 7):
"It is trite that the effect of the contract between the appellant and Case Credit, and specifically the question whether beneficial title to the goods passes under it, must be determined on the basis of the provisions of the contract itself, including the understanding of the parties as to its effect."