The amount of outstanding cheques of the taxpayer that it had issued to suppliers but which had not yet cleared were not includable in its capital. They did not represent an "advance" ("something made before it is actually due") nor a "loan" ("a liability created between the lender and the borrower resulting from the advancing of the funds") (p. 2882).
There was no basis for extending the administrative policy of the Minister, that allowed corporations to offset cash balances against unpresented cheques, to permit the taxpayer to set-off bankers' acceptances and commercial paper against the amount of outstanding cheques.