In view of recent decisions, it is unnecessary for me to re-state the meaning and effect of this section. Its application depends upon whether there is here an arrangement having the purpose or effect of avoiding a liability for tax that would otherwise fall upon Dr. Peate. The facts stated indicate this purpose and this effect, for despite other reasons that were advanced by Dr. Peate for so much of what was done as consisted in putting Westbank in the place of the partnership, when all that was done is looked at and in particular when the role of Raleigh is examined, there is a strong prima facie case that the purpose and effect of what was done was to obtain increased tax deductions from assessable income and to divide what would otherwise have been Dr. Peate's taxable income between himself, his wife and his children. For Dr. Peate it was argued, however, that this conclusion should not be drawn. First, taking the language of Lord Denning in Newton v. Federal Commissioner of Taxation [1] , it was contended that it cannot be predicated by looking at what was done that the arrangement was to avoid tax and that it was explicable "by reference to ordinary business or family dealing". To arrange for the formation of a company in which all the shares would be held in trust for two children and then that Dr. Peate should transfer his professional practice, his books and his instruments to that company and become its servant in the practice of his profession upon the terms of the agreement to which I have already referred is not, to my mind, explicable by reference either to ordinary business or ordinary family dealings even when due weight is given to the circumstance that Dr. Peate, upon his becoming governing director, really had control of the company. There is little similarity between this case and Purcell's Case [2] where, a man having declared that he held certain property in trust for his wife and daughter, it was held, rightly in the view of the Privy Council, that the declaration was not avoided by s. 260. Nor do I think that the War Assets Case [3] shows that what took place here was an ordinary business transaction. Lest, however, it should be thought from my emphasis upon the part played by Raleigh that it is only the interposing of Raleigh between Dr. Peate and Westbank that prevents the arrangement as a whole being regarded as an ordinary business transaction, I should say that this is not my view. It is true that I do regard the incorporation of Raleigh and the seven other doctors' family companies as colouring everything that was done here but, even without this, I would have concluded that it was not an ordinary business transaction for a body of professional men who are entitled to sue for fees for medical services to transfer their practices, their libraries and their instruments to a company which could not sue for fees and to become that company's servants in the conduct of their profession, particularly in the circumstance that, to the extent to which patients paid fees to the company, their expenditure was not deductible under s. 82F. What, outside a profession, might be regarded as an ordinary business transaction may, within a profession, have an altogether different appearance. In the second place, although in the face of the decisions it could not be argued that s. 260 does not apply to future income, Mr. Jenkins did seek to limit its application to income derived from sources of income already in existence and it was pointed out that in cases such as Bell, Newton and Hancock when the arrangements were made the companies concerned had already in hand the funds from which the dividends that were treated as the income of the taxpayer were eventually paid. This submission is, I think, directly in conflict with the recent decisions of this Court in Millard v. Commissioner of Taxation [1] and Cecil Bros. Pty. Ltd. v. Federal Commissioner of Taxation [2] . In the former case Taylor J. held that s. 260 applied when a bookmaker carried on his business as a paid servant of a company he had formed and had returned his salary as his income. The decision was that the profits of the business gained after the introduction of the new order was the income of the bookmaker himself. In this case s. 260 was applied to what became profits but what were at the time of the arrangement moneys in the pockets of punters. In the later case Owen J. applied s. 260 to an arrangement for future business whereby the profits of the taxpayer were to be reduced by interposing between it and the supplier of goods another company which charged the taxpayer more than the supplier's price. From the judgments it does not seem that the point taken before me was taken in either case but, independently altogether of the authority in these cases, I do not regard it as a good argument and consider that s. 260 can apply to prospective income from future personal exertion as well as to prospective income from property. The language in which (a), (b), (c) and (d) of s. 260 is expressed affords no support for the appellant's argument. In Newton's Case [1] , their Lordships, in disposing of an argument that the avoidance with which s. 260 is concerned is nothing beyond the displacement of an accrued liability, said: - "Their Lordships cannot accept this submission. They are clearly of opinion that the word "avoid" is used in its ordinary sense - in the sense in which a person is said to avoid something which is about to happen to him. He takes steps to get out of the way of it. It is this meaning of "avoid" which gives the clue to the meaning of "liability imposed". To "avoid a liability imposed" on you means to take steps to get out of the reach of a liability which is about to fall on you. If the submission of Sir Garfield Barwick were accepted, it would deprive the words of any effect: for no one can displace a liability to tax which has already accrued due, or in respect of income which has already been derived" [2] . It appears to me that in 1956 Dr. Peate and the other doctors did what they did to get out of the way of taxation which was in prospect if they were to carry on their professional practice in partnership as they had theretofore and that this, in the circumstances stated, is sufficient to meet the test propounded by their Lordships. I conclude, therefore, that s. 260 applies.