Principal Issues: What would be the cost amount of a promissory note received by a Canadian taxpayer from a private corporation for the payment of a capital dividend?
Position: The cost amount would be an amount equal to the principal amount of such promissory note.
Reasons: Based on a textual, contextual and purposive interpretation of the Act the cost amount of a promissory note received by a Canadian taxpayer for the payment of a capital dividend would be equal to the principal amount of such promissory note, which provides for a result