The taxpayers donated paintings to a museum. In upholding the Minister's valuation (less than 10% of the taxpayers') and rejecting a submission that the museum represents a "special purchaser" (a buyer willing to pay more than others because of a special need or interest), Bédard J. noted that a special purchase can raise the fair market value of property, but the existence of such a buyer must be well supported in evidence.
Bédard J. also noted that, in a very small market, the hypothetical sale of the property in question might itself amount to a substantial increase in supply, which would reduce the property's marginal fair market value accordingly.