R. v. Kleysen, 96 DTC 6265, [1996] 2 CTC 201 (Man QB) -- summary under Subsection 69(3)

After noting the submission for the accused that the relevant valuation test for sale of equipment by Canadian taxpayers to a related off-shore entity was the "reasonable amount" test in s. 69(3) rather than the "fair market value" test in s. 69(1), Schwartz J. found (at p. 6284) that he was not satisfied that the values used by the accused in their dealings with the off-shore corporation were unreasonable in all the circumstances.