Estate of Mary Rizak c/o George Jehn v. The Queen, 2008 DTC 4460, 2008 TCC 434 (Informal Procedure) -- summary under Paragraph 20(1)(c)

The taxpayer was unable to deduct interest on an alleged deferred obligation to subscribe for further shares in a company in which it had made an initial subscription for shares given that the only evidence of any legal obligation was a blank subscription agreement and given that (in light of the principle that interest is deductible only when it is payable, the alleged obligation to pay interest on the obligation did not arise until December 31 of a subsequent taxation year.