A dividend was income to the taxpayer in the year the dividend was declared in light of the "underlying assumption in the Income Tax Act that income from business or property will be determined by the accrual method of accounting". Mogan T.C.J. stated (at p. 253) that:
"I question whether any corporation is permitted to adopt the cash method of accounting if it is part of a corporate group having transactions with one or more other corporations in the group which carry on an active business."