The taxpayer was the sole shareholder and employee of a corporation. The corporation paid him his entire salary on December 31 each year, which he immediately lent back to the corporation and claimed as a bad debt. Noël stated (at para. 7):
The appellant cannot maintain at once that he made bona fide loans to his company and that the loans gave rise to bad debts on the very day on which they were advanced. A monetary loan, by definition, is an amount advanced in the expectation that it be repaid... .