 In the taxonomy of tax schemes the overall operation was a classic exploitation of income versus capital dichotomy.But there was no need for contrivance or collusion, the different tax treatment to each party simply made the transaction an advantage to both.The principal interest in the case today is its part in judicial interpretation of the section 260 anti-avoidance provisions of the "Income Tax Assessment Act 1936", and indirectly in overall dividend stripping operations of the time (insofar as action against the vendors' position failed).