Two companies that were vigorous competitors (Pioneer and Federal) each owned one-half of the shares of two other companies (Buckerfield's and Green Valley). In finding that Buckerfield's and Green Valley were associated corporations pursuant to s. 39(4)(b) of the pre-1972 Act by virtue of their control by the same group of persons, Jackett P. stated (at p. 5303):
Many approaches might conceivably be adopted in applying the word "control" in a statute such as the Income Tax Act to a corporation. It might, for example, refer to control by "management", where management and the board of directors are separate, or it might refer to control by the board of directors. ... The word "control" might conceivably refer to de facto control by one or more shareholders whether or not they hold a majority of shares. I am of the view, however, that in Section 39 of the Income Tax Act [the former section dealing with associated companies], the word "controlled" contemplates the right of control that rests in ownership of such a number of shares as carries with it the right to a majority of the votes in the election of the board of directors.
Jackett P. further stated (at pp. 5303-5304) that "the word 'group' in its ordinary meaning ... can refer to any number of persons from two to infinity".