Cash dividends paid by a corporation ("Old VIH") to its parent (the taxpayer) in February 1993 came out of safe income of Old VIH given that the computation of Old VIH's safe income included significant income that it had earned after its last fiscal year end (March 31, 1992) and before the date of payment of the dividends. Sharlow J.A. stated (at p. 5101) that