In finding that a purported issuance of preference shares was in fact a loan, with the result that the interest thereon was deductible, Cartwright J. noted (p. 1209) that the share:
"provisions are entirely inappropriate to describe the rights of a holder of preferred shares; they are an unequivocal and unconditional promise to pay the principal amount received from the holder at maturity and to pay interest thereon at 5 per cent per annum half-yearly on July 15 and January 15 until the principal has been paid."