Time Motors Limited v. Minister of National Revenue, 69 DTC 5149, [1969] CTC 190, [1969] S.C.R. 501 -- summary under Paragraph 18(1)(e)

The taxpayer, which was a used car dealer, issued credit notes in partial payments of used cars acquired for resale. The notes were not transferrable, were valid only within a stated period of time (generally one or two years) and were good only for the purchase of a car of the taxpayer of not less than a stated value. Pigeon J. found that the issuance of the credit note gave rise to an immediate enforceable obligation rather than a contingent liability after noting that the wording of s. 12(1)(e) "clearly refers to accounting practice" (p. 5151).