Before going on to find that the taxpayer was carrying on business by virtue of an arrangement under which he purchased a non-exclusive licence to exploit futures trading software and then entered into a "Agency Agreement" pursuant to which an entity connected with the licensor of the software to him traded in futures contracts on his behalf, Bell J. stated (at p. 2651):
"The law is clear that whenever an agent carries on business on behalf of a principal, the principal is deemed to be carrying on that business."