Before going on to find that s. 56(4) did not apply to royalty income derived from the taxpayer's interest as lessor in mining concessions and railway rights-of-way because that interest had been transferred by the taxpayer to a corporation in which its subsidiary had a 37% beneficial interest, McArthur TCJ. stated (at p. 912):
"Surely, the exclusionary words 'unless the income is from property' are not to be read so narrowly as to prohibit a taxpayer from benefiting from the exclusion when the income is from property which is an integral part of the taxpayer's business."