The Queen v. Littler, 78 DTC 6179, [1978] CTC 235 (FCA) -- summary under Paragraph 69(1)(b)

A sale by the taxpayer to his sons of shares for their market price at a time when the taxpayer had insider knowledge that an offer would be made for the shares at a price substantially higher than that market price was not a transaction whereby the taxpayer "dispose[d] of property directly or indirectly by way of gift" within the meaning of a former gift-tax provision of the Act. "A contract of sale, which is, by definition, a transfer of property for a consideration, cannot be a gift, which is, by definition, a disposition of property without consideration."