Bankers acceptances held by the taxpayer were not "advances" to the issuer because the issuer had no obligation to repay the same sum of money to the taxpayer or to provide any goods or services, and its only payment obligation to the taxpayer was a contingent obligation to pay the face amount if the accepting bank failed to do so. Furthermore, the bankers acceptances were not bonds, debentures, notes, mortgages or similar obligation because the bank alone was primarily liable to pay the holder. Sharlow JA stated: