The Saskatchewan Court of Queen's Bench pursuant to s. 22 of the Married Women's Property Act (Sask.) directed the Registrar of Land Titles to transfer title to two houses, then held by a company ("Saskan") which was owned by the taxpayer, to the taxpayer's divorced wife. Although counsel for the taxpayer had objected to an order for transfer of the property, he had asked that if such a transfer order were to be made it should be directed to the Registrar. In addition, the taxpayer had taken no action to have Saskan object to the transfer of the houses, and for these two reasons he had concurred in the transfer. There was a "benefit" to him because his property might have been ordered to be transferred instead of that of Saskan. S.56(2) accordingly included the value of the equities of redemption of the houses in his income.