O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295 -- summary under Payment & Receipt

Promissory notes owing by the taxpayers, which were consideration for their acquisition of units of a limited partnership, provided that the interest thereon was to be paid by way of set-off against distributions otherwise payable by the partnership to the taxpayers. In fact, the partnership did not generate distributable cash and, particularly for the first taxation year in question, there was no evidence that interest was paid through the making of timely journal entries. Accordingly, the amounts represented by the notes were limited recourse amounts.