The difference between the $152,078 purchase price for a Government of Canada Treasury Bill, which the taxpayer acquired on May 2, 1989, and its face value of $170,000, which the taxpayer received on the maturity of the treasury bill on April 27, 1990 was correctly treated by Revenue Canada as interest income for the taxpayer's 1990 taxation year, rather than as a payment of principal to which s. 39(4) applied. Stone, JA noted (at p. 5343) that "it is well established that, as a general rule, compensation for the use of money represents interest," that there was "no suggestion of any accretion to capital between the date the bill was acquired and the date it was redeemed," and that it was apparent that a holder of a treasury bill is paid a blend of principal and interest upon its redemption.
