The taxpayer disposed of a property to a related company for $800,000. The taxpayer's appraiser had estimated the property's value to be $850,000, based on an estimated value range of $786,590 to $898,960, and the Minister assessed under s. 69 on the basis that the taxpayer's proceeds of disposition were $850,000. C Miller J stated (at para. 131):
Real estate appraisals, especially where there are exceptional non-market forces at work, cannot be precise. A range of value makes eminent sense. And, where a taxpayer has designated a value that ultimately is found to fall within the range of reasonable fair market value, I see no reason to disturb that figure. $800,000 it is.