Before going on to find that a shareholder benefit had been conferred on the taxpayer by virtue of his transferring a property to a corporation of which he was a majority shareholder for a price that was 50% higher than the property's fair market value, Angers J. stated (at p. 2580):
"This Court dealt at length with the concept of market value in relation to the concept of the purchaser having a special interest, and it acknowledged that it is possible, in certain circumstances, for a purchaser to have a special interest in acquiring property for a price higher than what otherwise [it] would be prepared to pay."
On the facts here, no special value of the property to the corporation was established.