Before finding that a demand promissory note signed by the taxpayer to evidence a loan made to him by a corporation he controlled did not represent a bona fide arrangement for repayment within a reasonable time, Lamarre Proulx TCJ. referred to the Perlingieri case (93 DTC 158) and stated (at p. 675):
"It is clear that an important feature of the Appellants's legal situation regarding the demand note signed by him is that he owned 98% of the voting shares of the corporation from which he had obtained the loan. In such circumstances, it is impossible to consider a demand loan as a binding agreement between the corporation and its debtor."