After finding that a shareholder benefit was conferred on the taxpayer when he transferred a property to a corporation of which he was majority shareholder for a sale price 50% higher than the property's fair market value, Angers J. stated (at p. 2582):
"Under that case law, the application of subsection 15(1) of the Act does not require an intent to confer a benefit on the shareholder. It is enough that the shareholder knew or should have known, given the facts in the case, that he was receiving a benefit further to the transaction at issue ... . The appellant and his accountant made no effort to determine the property's fair market value prior to the transfer."