Respecting the transfer of inventory by a cattle farmer for a promissory note, CRA stated:
[B]oth the Bill of Sale and the Purchase and Sale Agreement refer to the promissory note as the consideration given for the transfer of the inventory. Since the promissory note was accepted as consideration for the transfer of the inventory, and given that none of the documents provide any remedy for non-payment, it appears that payment could only be enforced under the terms of the promissory note. Therefore, on the basis of the documents submitted, it is our view that the promissory note constitutes absolute payment and … pursuant to subsections 28(1) and 76(1) of the Act, the amount of the promissory note received in respect of the cattle and feed inventory should have been included in the taxpayer's income for the year of the disposition.