Before finding that the taxpayer had failed to discharge the onus on him to establish that money borrowed by him had been used by him to invest in companies owned by him, the Court rejected the (at para. 12) taxpayer's argument that:
"the only difference between his case and Singleton is that he did not bother with the formalities, that is, he did not withdraw his equity from his companies and replace it with borrowed money, but in substance his transaction achieves the same result."