Cooper v. The Queen, 88 DTC 6525, [1989] 1 CTC 66 (FCTD) -- summary under Subsection 105(1)

The taxpayer, who was a residuary beneficiary and executor of his mother's estate, was held not to have received a benefit by virtue of an interest-free $400,000 loan made to him by the executors for the purpose of buying himself a home. Rouleau, J. was influenced by the fact that specific legislation dealing with interest-free loans (section 80.4) made no reference to loans made by a trust, and also noted (at p. 6535) that "Any loan which escapes inclusion into income under subsection 15(2) must be understood to have escaped entirely whether interest-free or not, otherwise the purpose of the section is in part defeated."