R. v. Century 21 Ramos Realty Inc., 87 DTC 5158, [1987] 1 CTC 340 (Ont.C.A.) -- summary under Subsection 15(1)

The summary conviction appeal court judge indicated that even if shares received by the accused had a value of only $25, the accused should still have included $25,000 in his return because all the parties concerned, including him, were of the belief that the shares had a value of $25,000. The Court of Appeal held that the belief of the accused was immaterial and it is "only the 'amount or value' of the property appropriated to or for the benefit of the shareholder that must be included in computing the income of the shareholder".