Hudson Bay Mining and Smelting Co., Ltd. v. The Queen, 86 DTC 6244, [1986] 1 CTC 484 (FCTD), aff'd 89 DTC 5515 (FCA) -- summary under Paragraph 110.1(1)(a)

The sale by the taxpayer to the Manitoba Hydro-Electric Board of hydro facilities for what was agreed upon in the negotiations to be a net price of $750,000 was effected by Manitoba Hydro purchasing the assets for $3,600,000 and the taxpayer making a "gift" to Manitoba Hydro of $2,850,000. Since the evidence established that the two payments were interdependent, the $2,850,000 payment could not be said to have been made gratuitously, and was not a "gift".