McDonald
J.A.:
—
We
are
all
of
the
view
that
the
Tax
Court
Judge
committed
no
error
in
law
in
deciding
the
issues
before
him
as
he
did.
We
agree
with
him
that
a
benefit
was
received
by
the
shareholder
and
was
therefore
properly
taxable
in
his
hands.
In
our
view
he
was
also
correct
in
concluding
that
the
value
of
the
benefit
was
not
reduced
by
credit
balances
in
the
shareholders
loan
accounts
for
the
years
in
question
as
there
was
no
connection
between
the
loan
and
the
costs
incurred
in
acquiring
the
property.
For
the
reasons
given
in
the
Youngman
decision
by
this
Court,
the
use
of
a
cost
computation
based
on
the
interest
applicable
to
the
cost
of
the
property
was
in
our
view
an
appropriate
method
of
calculating
the
value
of
this
benefit
as
opposed
to
a
market
value
assessment.
The
appeal
will
be
dismissed
with
costs.
Appeal
dismissed.
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