Inland Revenue Commissioners vs Lawrence, Graham & Co. on 3 March, 1937
"During the course of the trading this company committed a breach of the law. As I say, it has been agreed that they did not intend to do anything wrong in the sense that they willingly and knowingly sending these goods to an enemy destination : but they committed a breach of the law, and for that breach of the law they were fined. That, as it seems to me, was not a loss connected with the business, but was a fine imposed upon the company personally, so far as a company can be considered to be a person, for a breach of the law which it had committed. It is perhaps a little difficult to put the distinction into very exact language, but there seems to me to be a difference between a commercial loss in trading and a penalty imposed upon a person or a company for a breach of the law which they have committed in that trading, for that reason I thing that both the decision of Rowlatt, J., in this case, and his former decision in Inland Revenue Commissioner v. Warnes & Co. which he followed, were right, and that this appeal should be dismissed with costs.