Bankers' acceptances purchased by the taxpayer were not eligible for an investment allowance. In finding that they did not qualify as an "advance" under s. 181.2(4)(b), Mogan TCJ. stated (at p. 1951):
"An 'advance' in the context of that phrase ['loans and advances'] is an amount paid before the completion of an obligation for which it is to be paid; or an amount paid before the performance of a resulting reciprocal obligation. In that sense, an amount paid by the Appellant for the purchase of a BA is the cost of an investment and not an advance to another corporation."
In finding that bankers' acceptances were not notes for purposes of s. 181.2(4)(c), Mogan TCJ. noted that the accepting bank is the party primarily liable to the holder in due course of a BA and found that as a BA is not a debt instrument, it is not described in s. 181.2(4)(c) which is concerned only with obligations having the character of a debt.