Goulet v. The Queen, 2009 DTC 1875, 2009 TCC 127 (Informal Procedure), aff'd 2011 DTC 5138 [at 6120], 2011 FCA 164 -- summary under Paragraph 12(1)(c)

In finding that the difference between the purchase price of notes and of commercial paper acquired by the taxpayer in the secondary market and their redemption price was interest to the taxpayer, Bédard, J. rejected the taxpayer's submission (at para. 6) that s. 12(9) of the Act and Regulation 7000(2) applied only to taxpayers who held prescribed debt obligations that were acquired at the time of their issue. He then went on to find that even in the absence of the above provisions, the discounts received by the taxpayer would have been interest income to him on general principles given that the taxpayer did not establish that the rate of return for these obligations reflected a risk premium.