Dussault 7.C.J.:

The appellant is challenging an assessment for his 1991 taxation year by which the Minister of National Revenue (“the Minister”) contended that he had received a taxable benefit of $65,000 from 2541-4947 Québec Inc. (“the company”) under s. 15(1) of the Income Tax Act (“the Act”).

Rand, J.:—The appellant was incorporated by letters patent of the province of Quebec and among the objects were: