Goreham v. The Queen, 2000 DTC 1561 (TCC) -- summary under Subsection 15(2.4)

At the time the taxpayer received a loan from a company carrying on a fishing business that was beneficially owned, as to 50%, by the taxpayer and his wife, a written agreement was entered into under which it was agreed that he would repay the advances out of the proceeds of sale of his home and out of bonuses payable whenever he returned from a fishing voyage. It was found (at p. 1566) that this "agreement failed to provide a recognizable and reasonable termination date for payment of the loan" given that, at the time of the agreement, it was reasonably clear to the taxpayer and his wife that they would be unable to sell their home and given that the decision to pay the bonuses was within his complete control (and, in fact, there were a number of occasions in which he determined that the company would not pay him the bonuses).