Lyons J found (at para. 42) that the taxpayers were not required by Blue Hill, the promoter of a tax shelter investment in mineral claims, to pay the promissory notes issued by them in consideration for Blue Hill incurring Canadian resource expenditures on their behalf. On this basis, she found that the notes were a prescribed benefit under Reg. 231(6) (now Reg. 31001).).
See summary under s. 237.1(1) – tax shelter.